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sd-10-EFTA01358962Dept. of Justice

EFTA Document EFTA01358962

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Page 30 874 F.3d 787, *; 2017 U.S. App. LEXIS 20596, "; Bankr. L. Rep. (CCH) P83,176; 64 Bankr. Ct. Dec. 216 The Subordinated Notes holders argue that the Fourth Proviso carves out the Second-Lien Notes from the Baseline Definition, i.e., that the Second-Lien Notes are an "[i]ndebtedness or obligation of the Company . . . that by its terms is subordinate or junior in any respect to any other Indebtedness of the Company." The Subordinated Notes holders rely heavily on the "in r13] any resp

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sd-10-EFTA01358962
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