Amaru Settlement for 30 cents on the dollar.

7/27/2019 Amaru Settlement for 30 cents on the dollar.

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Case 2:06-bk-11205-VZ Doc 1417 Filed 06/17/13 Entered 06/17/13 14:58:41 DescMain Document Page 1 of 22


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1016185.1 25382 10

6. As to components (b) through (e) of the Claim, I assert that Shakur has not

made a prima face case and Shakur is, indeed, agreeing to their disallowance in their entirety.

However, as a compromise, I agree to the allowance of one component of the Claim, component

a relating to the final arbitration award. Absent this compromise, I am informed and believe thatlitigation would proceed on all five components of the Claim, each of which involves factual and

legal issues. I am well aware that there are costs and risks always attendant to litigation. Given the

number of legal and factual issues, I am informed and believe that litigation, including discovery,

could be extensive.

7. The Settlement Agreement proposed herein would benefit the Consolidated Estates

creditors because it reduces a claim of $2,218,121.76, by nearly 70% to $668,121.76. I have

obtained the disallowance of four out of five of the components of Shakurs Claim while agreeing

to the allowance of the stronger fifth component. I conclude based on my experience and business

judgment that, ultimately, this compromise results in a substantial benefit to the remaining

unsecured creditors, treats the Claimant fairly, and succeeds in avoiding the undue risk and expense

of further litigation. I believe that extensive litigation which would likely be necessary in this

proceeding does not appear to be economically warranted in light the projected magnitude of

distributions to allowed general unsecured claims.

I declare under penalty of perjury under the laws of the United States of America that the

foregoing is true and correct.

Executed June ____, 2013, at Los Angeles, California.

R. TODD NEILSON



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Amaru Settlement for 30 cents on the dollar.

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