3. Would you vote for the modified reorganization plan?

We have two choices for now new modified reorganization plan and /or
liquidity. if we analyze these two scenarios then in
Case: 1
Reorganization
$10 million in equity AHC
$25 million in senior secured debts and $10 million in junior secured
debts
$55 million non-interest bearing performance linked obligation under
certain conditions
Moreover they have performance-linked obligation
The conditions for performance-linked obligation are:
10 year maturity obligation
Possibility of converting into cash or new debt of ASP at maturity
Conversion option tied to ASP performance in the final 3 years of
obligation life
If the average net profit of the period is BELOW$40 million, there would
be no conversion
If the average net profit of the period is ABOVE $130 million, there
would be 100% conversion
To support reorganization we have forecast data from management and
credit agricole

Under the management forecast, there will be the possibility of

converting the $55 million at maturity, however, it will not be 100%
Under Credit Agricole projections, at maturity there will not be any
conversion since the average for the last three years is below $40
million
In order to provide a better solution, we took into account the
probability of both scenarios happening, there 50% of chance each
Our results are shown above, which will be $76 million for the last 3 years,
meaning that there will be conversion of the debt, but not at 100%
Case 2:

Liquidity
$20 million in senior secured debt
$8 million in junior secured debt

Creditors might spend as long as 15 years in court to claim their rights

Such that we say yes to reorganization plan because :

If the creditors allowed the firm to liquidate, at the most they would get
$28 million, but that might take up to 15 years to settle
Rehabilitation plan would offer minimum of $45 million in debt and
equity, plus the possibility of converting the performance related
obligations at maturity