“‘Equitization’ means, if the Sale Course of doesn’t consequence within the sale of all or considerably all the belongings of Genesis, a restructuring beneath the Amended Plan pursuant to which the GGC Collectors will obtain, amongst different issues, a hundred percent (100%) of the fairness in reorganized GGH, topic to dilution by a administration incentive program which may be applied with the approval of the Chapter Court docket, upon discover and listening to,” the submitting stated.

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