E. Pipelines, Land and Facilities
· Pipelines, Land, and Facilities consists of approximately 935 miles of pipelines located in East Texas and Louisiana in the Haynesville Shale.
· The pro forma book value is expected to be zero as these assets will transfer to BTA on the Sale Closing Date
F. Transloading Assets
· Transloading assets consist of eight skid transloaders and eight ladder transloaders located at a storage facility in Salt Lake City, Utah.
· The transloading assets were not included in the Sale Transaction.
· The Liquidation Analysis estimated recovery for these assets factors in an accelerated time frame of a proposed asset sale, low demand for these asset types in the current market and an overall lack of industry liquidity and financing sources.
· The Liquidation Analysis assumes a recovery 9.9% to 11.5% of the pro forma balance.
G. Construction in Progress
· All construction in progress assets are assumed to transfer to BTA on the Sale Closing Date.
· The Liquidation Analysis assumes the pro forma balance for these assets is zero.
H. Liquidation Adjustments
· Estate Wind-Down Costs: consist primarily of general and administrative support functions that would be required to wind-down the Chapter 7 Estate. These wind-down functions are assumed to occur over a 6-month period concurrently with the monetization of any remaining Estate assets.
· Professional Fees: include estimates for certain professionals required during the wind down period and are estimated at a range of 0.2% to 0.6% of gross liquidation proceeds.
· Trustee Fees: Section 326 of the Bankruptcy Code provides for Trustee fees of 3% for liquidation proceeds in excess of $1 million. The Liquidation Analysis, therefore, assumes Trustee fees are 3% of proceeds available for distribution to creditors.