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1265. Plaintiff cannot at this time identify each and every one of the voluminous claims thatmay have been filed by, on behalf of, or for the benefit of any of the Subordination Defendants,because information necessary to make this determination is exclusively in the possession of others.The Court should exercise the full extent of its equitable powers to ensure that all claims, paymentsand benefits, of whatever kind or nature, which have been or may be asserted against theSubordination Plaintiff by, on behalf of, or for the benefit of the Subordination Defendants, in anycapacity, directly or indirectly, are subordinated pursuant to sections 510(c)(1) and 105(a) of theBankruptcy Code. No funds which would otherwise be paid to creditors should be paid to any ofthe Subordination Defendants.1266. Equitable subordination as requested herein is consistent with the provisions andpurposes of the Bankruptcy Code.1266A. For the reasons alleged in this Count 73, to the extent that any of the SubordinationDefendants is determined to have a lien on property of the Subordination Plaintiff’s estate, the Courtshould enter an order transferring such lien to the Subordination Plaintiff’s estate, pursuant tosections 510(c)(2) and 105(a) of the Bankruptcy Code.COUNT 73A(Equitable Subordination Under Sections 510(c)(1)-(2) and 105(a) of theBankruptcy Code; Against Claim Transferee Defendants)1266B. The allegations in paragraphs 1 through 1266A of this Complaint are incorporatedherein by reference.1266C. This Count is brought on behalf of Subordination Plaintiff.1266D. As of the Petition Date, some Defendants in this proceeding directly or indirectly heldinterests in claims against or obligations of Subordination Plaintiff which were subsequentlytransferred to others on or after the Petition Date. These interests in claims or obligations, whichDefendants held as of the Petition Date but subsequently transferred, are referred to herein as604041v1/007457-415-