PLEASE TAKE NOTICE that on March 20, 2018, 21st Century Oncology Holdings,

Transcription

1 MainDate Document Docket #1035 Filed: 03/20/2018 Pg 1 of 43 Hearing Date and Time: April 24, 2018 at 10:00 a.m. (prevailing Eastern Time) Objection Deadline: April 12, 2018 at 4:00 p.m. (prevailing Eastern Time) Jeffrey R. Gleit, Esq. Allison H. Weiss, Esq. SULLIVAN & WORCESTER LLP 1633 Broadway New York, New York (212) (Telephone) (212) (Facsimile) Counsel to the Reorganized Debtors UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: 21st CENTURY ONCOLOGY HOLDINGS, INC., et al.,1 Reorganized Debtors. ) ) ) ) ) ) ) Chapter 11 Case No (RDD) (Jointly Administered) NOTICE OF HEARING ON REORGANIZED DEBTORS FIRST OMNIBUS OBJECTION TO CLAIMS SEEKING TO DISALLOW AND EXPUNGE (1) LATE FILED CLAIMS, (2) AMENDED AND SUPERSEDED CLAIMS AND (3) DUPLICATE CLAIMS PLEASE TAKE NOTICE that on March 20, 2018, Holdings, Inc. and its reorganized debtor affiliates (collectively, the Debtors and after the Effective Date of the Plan, as defined herein, the Reorganized Debtors ), filed the annexed First Omnibus Claims Objection (the First Omnibus Objection ), pursuant to sections 105(a) and 502(b) of title 11 of the United States Code (the Bankruptcy Code ), Rule 3007 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ), and the omnibus claims objection procedures (the Omnibus Claims Objection Procedures ), as approved by the Bankruptcy Court (defined 1 Each of the Reorganized Debtors in the above-captioned jointly administered chapter 11 cases and their respective tax identification numbers are set forth in the Order Directing Joint Administration of Chapter 11 Cases [Docket No. 30]. The location of Holdings, Inc. s corporate headquarters and the Debtors service address is: 2270 Colonial Boulevard, Fort Myers, Florida h;f2#4 %,«

2 Pg 2 of 43 Main Document herein) by that certain Order dated March 12, 2018 [Docket No. 1023] (the Omnibus Claims Objection Procedures Order ). PLEASE TAKE FURTHER NOTICE that the First Omnibus Objection is scheduled to be heard on April 24, 2018 at 10:00 a.m. (Eastern Time) (the Hearing ) before the Honorable Robert D. Drain, United States Bankruptcy Court for the Southern District of New York, 300 Quarropas Street, White Plains, New York, (the Bankruptcy Court ). PLEASE TAKE FURTHER NOTICE that responses, if any, to the First Omnibus Objection (the Responses ) shall (i) be in writing, (ii) conform to the Omnibus Claims Objection Procedures, the Bankruptcy Rules, the Local Bankruptcy Rules for the Southern District of New York, and the Final Order (I) Establishing Certain Notice, Case Management, and Administrative Procedures and (II) Granting Related Relief [Docket No. 125] (the Case Management Order ), (iii) be filed with the Bankruptcy Court (a) by registered users of the Bankruptcy Court s case filing system, electronically in accordance with General Order M 399 (which can be found at and (b) by all other parties in interest, on a CD-ROM, in text-searchable portable document format (PDF) (with a hard copy delivered directly to Chambers as set forth in the Case Management Order), in accordance with the customary practices of the Bankruptcy Court and General Order M 399, to the extent applicable, and (iv) served upon the Notice Parties (as defined in the Omnibus Claims Objection Procedures) so as to be actually received on or before April 12, 2018, at 4:00 p.m. (prevailing Eastern Time) (the Response Deadline ). PLEASE TAKE FURTHER NOTICE that, if no Responses are timely filed and served with respect to the First Omnibus Objection in accordance with this notice, the Reorganized Debtors may, on or after the Response Deadline, submit to the Bankruptcy Court an order 2

3 Pg 3 of 43 Main Document substantially in the form of the proposed order annexed as Exhibit A to the First Omnibus Objection, which order may be entered with no further notice or opportunity to be heard. PLEASE TAKE FURTHER NOTICE that the Hearing may be continued or adjourned thereafter from time to time without further notice other than an announcement of the adjourned date or dates in open court at the Hearing. PLEASE TAKE FURTHER NOTICE that copies of the First Omnibus Objection, Case Management Order and all other documents filed in the chapter 11 cases may be obtained free of charge by visiting the website of Kurtzman Carson Consultants LLC, at You may also obtain copies of any pleadings by visiting the Bankruptcy Court s website at in accordance with the procedures and fees set forth therein. Dated: New York, New York March 20, 2018 SULLIVAN & WORCESTER LLP By: /s/ Jeffrey R. Gleit Jeffrey R. Gleit, Esq. Allison H. Weiss, Esq Broadway New York, New York (212) (Telephone) (212) (Facsimile) jgleit@sandw.com aweiss@sandw.com Counsel for the Reorganized Debtors 3

4 Pg 4 of 43 Main Document Hearing Date and Time: April 24, 2018 at 10:00 a.m. (prevailing Eastern Time) Objection Deadline: April 12, 2018 at 4:00 p.m. (prevailing Eastern Time) Jeffrey R. Gleit, Esq. Allison H. Weiss, Esq. SULLIVAN & WORCESTER LLP 1633 Broadway New York, New York (212) (Telephone) (212) (Facsimile) Counsel to the Reorganized Debtors UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: 21st CENTURY ONCOLOGY HOLDINGS, INC., et al.,1 Reorganized Debtors. ) ) ) ) ) ) ) Chapter 11 Case No (RDD) (Jointly Administered) REORGANIZED DEBTORS FIRST OMNIBUS OBJECTION TO CLAIMS SEEKING TO DISALLOW AND EXPUNGE (1) LATE FILED CLAIMS, (2) AMENDED AND SUPERSEDED CLAIMS AND (3) DUPLICATE CLAIMS THIS OBJECTION SEEKS TO DISALLOW AND EXPUNGE CERTAIN FILED PROOFS OF CLAIM. CLAIMANTS RECEIVING THIS OBJECTION SHOULD LOCATE THEIR NAMES AND CLAIMS ON THE EXHIBIT(S) ATTACHED TO THIS OBJECTION. IF YOU HAVE ANY QUESTIONS REGARDING THE OBJECTION, PLEASE CONTACT THE REORGANIZED DEBTORS COUNSEL, NATHANIEL R.B. KOSLOF, AT (617) Each of the Reorganized Debtors in the above-captioned jointly administered chapter 11 cases and their respective tax identification numbers are set forth in the Order Directing Joint Administration of Chapter 11 Cases [Docket No. 30]. The location of Holdings, Inc. s corporate headquarters and the Debtors service address is: 2270 Colonial Boulevard, Fort Myers, Florida

5 Pg 5 of 43 Main Document Holdings, Inc. and its reorganized debtor affiliates (collectively, the Debtors and after the Effective Date of the Plan, as defined herein, the Reorganized Debtors ), by and through their undersigned counsel, hereby file this first omnibus objection to claims (the First Omnibus Objection ) seeking to disallow and expunge: (i) the Claims (as defined herein), (ii) the Amended and Superseded Claims (as defined herein), and (iii) the Duplicate Claims (as defined herein). In support of the First Omnibus Objection, the Reorganized Debtors respectfully represent: Jurisdiction and Venue 1. The United States Bankruptcy Court for the Southern District of New York (the Bankruptcy Court ) has jurisdiction over this matter pursuant to 28 U.S.C. 157 and This matter is a core proceeding within the meaning of 28 U.S.C. 157(b)(2). 2. Venue is proper pursuant to 28 U.S.C and The statutory bases for the relief requested herein are sections 105(a) and 502(a) of chapter 11 of title 11 of the United States Code (the Bankruptcy Code ) and Bankruptcy Rule Background 4. On May 25, 2017 (the Petition Date ), each of the Debtors filed a voluntary petition for relief under the Bankruptcy Code. The Debtors operated their businesses and managed their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. On May 26, 2017, the Court entered an order [Docket No. 30] authorizing the joint administration and procedural consolidation of the chapter 11 cases pursuant to Bankruptcy Rule 1015(b). No request for the appointment of a trustee or examiner was made in the chapter 11 cases. On June 15, 2017, the United States Trustee for the Southern District of New 2

6 Pg 6 of 43 Main Document York (the U.S. Trustee ) appointed an official committee of unsecured creditors pursuant to section 1102 of the Bankruptcy Code (the Committee ) [Docket No. 92]. On June 16, 2017, the U.S. Trustee filed an Amended Notice of Appointment of Official Committee of Unsecured Creditors [Docket No. 94]. 5. On January 11, 2018, the Court entered the Findings of Fact, Conclusions of Law, and Order Confirming the Joint Chapter 11 Plan of Reorganization of 21 st Century Oncology Holdings, Inc. and Its Debtor Affiliates Pursuant to Chapter 11 of the Bankruptcy Code [Docket No. 915] (the Confirmation Order ) confirming the Debtors Joint Chapter 11 Plan of Reorganization of 21 st Century Oncology Holdings, Inc. and Its Debtor Affiliates Pursuant to Chapter 11 of the Bankruptcy Code [Docket No. 522] (the Plan ).2 The effective date of the Plan occurred on January 16, 2018 [Docket No. 919] (the Effective Date ). 6. Pursuant to the Plan, after the Effective Date, the Reorganized Debtors shall have the sole authority: (1) to File, withdraw or litigate to judgment objections to Claims or Interests; (2) to settle or compromise any Disputed Claim or Disputed Interest without any further notice to or action, order or approval by the Bankruptcy Court; and (3) to administer and adjust the Claims Register to reflect any such settlements or compromises without any further notice to or action, order, or approval by the Bankruptcy Court. Plan, Art. VII, Section 7.2; see also Confirmation Order, 64 (expressly reserving [a]ll rights of the Debtors and the Reorganized Debtors to challenge, object to, or seek to reclassify Claims and Interests... ). Furthermore, the Plan provides that [a]fter the Effective Date, each of the Reorganized Debtors shall have and retain any and all rights and defenses its predecessor Debtor had with respect to any Claim or Interest immediately before the Effective Date. Plan, Art. VII, Section Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Plan. 3

7 Pg 7 of 43 Main Document Claims Reconciliation Process 7. On May 26, 2017, the Bankruptcy Court entered the Order Extending Time to File Schedules of Assets and Liabilities, Schedules of Current Income and Expenditures, Schedules of Executory Contracts and Unexpired Leases, Statements of Financial Affairs, and Rule Financial Reports [Docket No. 34], and on July 10, 2017, the Debtors filed their respective statements of financial affairs and schedules of assets and liabilities on each Debtors respective chapter 11 docket [see, e.g., Docket Nos. 190 and 192], pursuant to Bankruptcy Rule On July 24, 2017, the Court entered an Order (A) Setting a Bar Date for Filing Proofs of Claim, Including Claims Arising Under Section 503(B)(9) of the Bankruptcy Code, (B) Setting a Bar Date for the Filing Of Proofs of Claim By Governmental Units, (C) Setting an Amended Schedules Bar Date, (D) Setting Rejection Damages Bar Date, (E) Approving the Form of and Manner for Filing Proofs of Claim, (F) Approving Notice of the Bar Dates, and (G) Granting Related Relief (the Bar Date Order ) [Docket No. 253], pursuant to which the Bankruptcy Court, among other things, established September 5, 2017, at 5:00 p.m. (prevailing Eastern Time), as the deadline for all non-governmental entities holding or wishing to assert a claim (as defined in section 101(5) of the Bankruptcy Code).3 9. On July 28, 2017, Kurtzman Carson Consultants LLC (the Claims and Noticing Agent ) provided notice of the Bar Date Order, in accordance with the procedures outlined therein (the Bar Date Notice ) to thousands of potential claimants. See Affidavit of Service of Darlene Calderon (the Affidavit of Service ) [Docket No. 284]. 3 The Bar Date Order established November 21, 2017, at 5:00 p.m. (prevailing Eastern Time) as the deadline for all governmental units asserting a claim (as defined in section 101(5) of the Bankruptcy Code) against the Debtors that arose on or prior to the Petition Date to file written proof of such claim. 4

8 10. Pg 8 of 43 Main Document Further, on August 24, 2017, the Claims and Noticing Agent provided the Bar Date Notice to additional potential claimants, in accordance with the procedures outlined in the Bar Date Order. See Supplemental Affidavit of Service of Darlene Calderon (the Supplemental Affidavit of Service ) [Docket No. 364]. 11. In addition to serving the Bar Date Notice individually on thousands of potential claimants on July 28, 2017 and August 24, 2017, respectively, copies of the Bar Date Order were made publicly available at and notices were published in the following publications: (i) USA Today (National Edition), (ii) Florida Times-Union, (iii) Palm Beach Post, (iv) Fort Myers News-Press, (v) Cape Coral Daily Breeze, (vi) Seattle Times, (vii) Gettysburg Times, (viii) South Jersey Times, (ix) Birmingham News, (x) Baltimore Sun, (xi) The Aegis, (xii) Washington Post, (xiii) Frankfort State Journal, (xiv) Myrtle Beach Sun News, (xv) Arizona Republic, (xvi) Bluefield Daily Telegraph, (xvii) Las Vegas Review-Journal, (xviii) Worcester Telegram & Gazette, (xix) The Daily Herald, (xx) Sampson Independent, (xxi) Goldsboro News-Argus, and (xxii) Oakland Press. See Affidavits of Publication filed by Christopher Marcus [Docket Nos , , , , ; ]. 12. During these chapter 11 cases, 2,705 proofs of claim were filed against the Debtors estates, in the aggregate amount of approximately $729,000, Of the 2,705 filed proofs of claim, the Debtors expunged or otherwise revolved 1,136 Proofs of Claim, in the aggregate amount of approximately $323,000,000.00, during the Chapter 11 Cases. 13. The Reorganized Debtors intend to proceed expeditiously towards expunging and resolving the remaining Proofs of Claim. In that vein, on February 14, 2018, the Reorganized Debtors filed The Reorganized Debtors Motion for Entry of an Order (I) Approving (A) Omnibus Claims Objection Procedures and (B) Omnibus Claims Satisfaction Procedures, (II) 5

9 Pg 9 of 43 Main Document Authorizing the Reorganized Debtors to File Substantive Omnibus Objections to Claims Pursuant to Bankruptcy Rule 3007(c), (d) and (e), and (III) Waiving the Requirement of Bankruptcy Rule 3007(e)(6) [Docket No. 964] (the Omnibus Claims Objection Procedures Motion ), to establish omnibus objection and satisfaction procedures (the Omnibus Claims Objection Procedures ) to resolve the remaining Proofs of Claim. 14. On March 12, 2018, the Bankruptcy Court granted the Omnibus Claims Objections Procedures Motion and entered an Order [Docket No. 1023] (the Omnibus Claims Objection Procedures Order ) approving the Omnibus Claims Objection Procedures. Relief Requested 15. The Reorganized Debtors file this First Omnibus Objection pursuant to sections 105(a) and 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007, and the Omnibus Claims Objection Procedures, as approved by the Omnibus Claims Objection Procedures Order, seeking the entry of an order, substantially in the form annexed hereto as Exhibit A (the Proposed Order ), disallowing and expunging: (1) the proofs of claim identified on Exhibit 1 of the Proposed Order listed under the heading Claims (collectively, the Claims ); (2) the proofs of claim identified on Exhibit 2 of the Proposed Order listed under the heading Amended and Superseded Claims (collectively, the Amended and Superseded Claims ); and (3) the proofs of claim identified on Exhibit 3 of the Proposed Order listed under the heading Duplicate Claims (collectively, the Duplicate Claims ). 16. The Reorganized Debtors also seek to preserve the right to later object to any Claim, Amended and Superseded Claim or Duplicate Claim to which the Bankruptcy Court does not grant the relief requested herein on any other basis. 6

10 Pg 10 of 43 Main Document The Claims Should be Disallowed and Expunged 17. objects. A filed proof of claim is deemed allowed, unless a party in interest U.S.C. 502(a). The Omnibus Claims Objection Procedures permit the Reorganized Debtors to file objections to more than one claim on the basis that, among other things, such claims were not timely filed. Omnibus Claims Objection Procedures at 1; Fed. R. Bankr. P. 3007(d)(4). Upon an objection, the claimant has the burden to demonstrate the validity of the claim. See In re Oneida, Ltd., 400 B.R. 384, 389 (Bankr. S.D.N.Y. 2009), aff d, No. 09 Civ (DC), 2010 WL , at *5 (S.D.N.Y. Jan. 22, 2010); In re Adelphia Commc ns Corp., Ch. 11 Case No , 2007 Bankr. LEXIS 660, at *15 (Bankr. S.D.N.Y. Feb. 20, 2007); In re Rockefeller Ctr. Props., 272 B.R. 524, 539 (Bankr. S.D.N.Y. 2000). 18. Bankruptcy Rule 3003(c) requires the bankruptcy court set a bar date after which proofs of claim may not be filed. Fed.R. Bankr. P. 3003(c) ( The court shall fix... the time within which proofs of claim or interest may be filed. ). Bar dates are critically important to the administration of a successful chapter 11 case. In re Musicland Holding Corp., 356 B.R. 603, 607 (Bankr. S.D.N.Y. 2006). They are not designed merely as a procedural gauntlet, but rather serve as an integral part of the reorganization process and the efficient administration of bankruptcy cases. In re Hooker Invest., Inc., 937 F.2d 833, 840 (2d Cir. 1991). 19. In this case, the Bar Date Order established, inter alia, (i) September 5, 2017, at 5:00 p.m. (prevailing Eastern Time), as the deadline for all non-governmental entities holding or wishing to assert a claim (the Claims Bar Date ), and (ii) November 21, 2017, at 5:00 p.m. (prevailing Eastern Time) as the deadline for all governmental units asserting a claim (the 7

11 Pg 11 of 43 Main Document Governmental Unit Bar Date, and together with the Governmental Unit Bar Date, the Bar Dates ). 20. The Bar Date Order provides that [i]f proofs of claim are not received by the Claims and Noticing Agent on or before the applicable Bar Date, the holders of the underlying claims shall be barred from asserting such claims against the Debtors and precluded from voting on any chapter 11 plans filed in these chapter 11 cases and/or receiving distributions from the Debtors on account of such claims in these chapter 11 cases. Bar Date Order at On July 28, 2017 and August 24, 2017, the Claims and Noticing Agent served the Bar Date Notice to thousands of potential claimants, in accordance with the procedures outlined in the Bar Date Order. See Affidavit of Service [Docket No. 284]; Supplemental Affidavit of Service [Docket No. 364]. In addition to serving individually on thousands of potential claimants, copies of the Bar Date Order were made publicly available at and notices were published in over twenty publications. See Affidavits of Publication filed by Christopher Marcus [Docket Nos , , , , ; ]. 22. The Bar Date Notice informed claimants specifically that the Bankruptcy Court established the Bar Dates and that claims would only be considered timely filed if actually received by the applicable Bar Date. Additionally, the Bar Date Notice and the Bar Date Order provide that claimants who do not timely file proofs of claim will be forever barred from recovery on such claims from the Debtors estates. See Bar Date Notice, Section V; Bar Date Order at The Claims do not comply with the Bankruptcy Code and the Bar Date Order because the Claims were not filed on or before the applicable Bar Date. 8

12 Pg 12 of 43 Main Document Indeed, section 502(b)(9) of the Bankruptcy Code provides, in relevant part, that a proof of claim should not be allowed if the proof of such claim is not timely filed U.S.C. 502(b)(9). Moreover, the Bar Date Notice provided to claimants that failure to timely file a proof of claim would result in such claim being barred. Nevertheless, the Late-Filed Claims were received after the applicable Bar Date. 24. Accordingly, the Reorganized Debtors seek entry of an order substantially in the form annexed hereto as Exhibit A, disallowing and expunging the Late-Filed Claims identified on Exhibit 1 of the Proposed Order. The Amended and Superseded Claims and the Duplicate Claims Should be Disallowed and Expunged 25. Pursuant to Article VII, Section 7.4 of the Plan, any Claim or Interest that has been amended or superseded, may be adjusted or expunged on the Claims Register by the Debtors or the Reorganized Debtors without an objection to such Claim or Interest having to be Filed and without any further notice to or action,order, or approval of the Bankruptcy Court. Notwithstanding, out of an abundance of caution, the Reorganized Debtors have included in the First Omnibus Objection the Amended and Superseded Claims. 26. A filed proof of claim is deemed allowed, unless a party in interest...objects. 11 U.S.C. 502(a). Bankruptcy Rule 3007(d) permits a debtor to file objections to more than one claim on the basis that, among other things, such claims duplicate other claims or have been amended by subsequently filed proofs of claim. Fed. R. Bankr. P. 3007(d)(1), (3). Upon an objection, the claimant has the burden to demonstrate the validity of the claim. See In re Oneida, Ltd., 400 B.R. 384, 389 (Bankr. S.D.N.Y. 2009), aff d, No. 09 Civ (DC), 2010 WL , at *5 (S.D.N.Y. Jan. 22, 2010); In re Adelphia Commc ns Corp., Ch. 11 Case No. 9

13 Pg 13 of 43 Main Document , 2007 Bankr. LEXIS 660, at *15 (Bankr. S.D.N.Y. Feb. 20, 2007); In re Rockefeller Ctr. Props., 272 B.R. 524, 539 (Bankr. S.D.N.Y. 2000). 27. Claims filed by the same creditor that are duplicate claims or amended and superseded by subsequent claims are routinely disallowed and expunged. See, e.g., In re Enron Corp., Case No. 01 B 16034(AJG), 2005 WL , at *1 n.1 (Bankr. S.D.N.Y. Oct. 5, 2005) (noting that [i]n as much as the Initial Claim was amended and superseded by the Amended Claim, it was disallowed and expunged.... ); In re Best Payphones, Inc., Case No , 2002 WL , at *4, 11 (Bankr. S.D.N.Y. Dec. 11, 2002) (expunging amended, duplicative claim). 28. A debtor cannot be required to pay on the same claim more than once, and a party cannot recover more than once for the same injury. See, e.g., In re Finley, Kumble, Wagner, Heine, Underberg, Manley, Myerson, & Carey, 160 B.R. 882, 894 (Bankr. S.D.N.Y. 1993) ( In bankruptcy, multiple recoveries for an identical injury are generally disallowed. ); Phelan v. Local 305 of United Ass n of Journeymen & Apprentices of Plumbing and Pipefitting Indus. of U.S. & Can., 973 F.2d 1050, 1063 (2d Cir. 1992); Singer v. Olympia Brewing Co., 878 F.2d 596, 600 (2d Cir. 1989); United States v. Zan Mach. Co., 803 F. Supp. 620, 623 (E.D.N.Y. 1992); see also Amerisource Corp. v. Rx USA Int l Inc., No , 2010 WL , at *6 (E.D.N.Y. May 26, 2010) (noting that equitable rules against double recovery and unjust enrichment would prevent the plaintiff from collecting damages under separate provisions of the same contract that compensate the plaintiff for the same loss); Leighty v. Brunn, 510 N.Y.S.2d 174, 175 (App. Div. 1986) ( It is beyond cavil that a plaintiff is entitled to only respect to an identical damage claim. ); Simon v. Royal Business Funds Corp., 310 N.Y.S.2d 409, (App. Div. 1970) (dismissing plaintiff s cause of action against 10

14 Pg 14 of 43 Main Document defendant where plaintiff s complaint failed to allege additional damages to those the plaintiff already recovered from a co-defendant in a separate proceeding). 29. The Reorganized Debtors have determined that (1) each Amended and Superseded Claim has been amended and superseded by a corresponding, subsequently-filed claim (each, a Surviving A&S Claim, and collectively, the Surviving A&S Claims ); and (2) each Duplicate Claim was filed by the relevant creditor in the same dollar amount, and based on the same obligations, as a corresponding claim (each, a Surviving Duplicate Claim, and collectively, the Surviving Duplicate Claims ). 30. To avoid the possibility of multiple recoveries by the same creditor and to maintain a more accurate claims register that does not inaccurately overstate the Reorganized Debtors liabilities, the Reorganized Debtors seek the entry of an order, substantially in the form annexed hereto as Exhibit A, disallowing and expunging from the claims register the Amended and Superseded Claims identified on Exhibit 2 of the Proposed Order, and the Duplicate Claims identified on Exhibit 3 of the Proposed Order. Reservation of Rights 31. The Reorganized Debtors hereby reserve the right to object in the future to any of the proofs of claim listed in the Exhibits to the Proposed Order on any ground, and to amend, modify, and/or supplement this First Omnibus Objection. A separate notice and hearing will be scheduled for any such objection. 32. The First Omnibus Objection does not affect any of the Surviving A&S Claims or the Surviving Duplicate Claims and does not constitute any admission or finding with respect to the allowance, disallowance, validity or value of the Surviving A&S Claims or the Surviving Duplicate Claims. 11

15 Pg 15 of 43 Main Document Notice 33. Notice of the First Omnibus Objection has been provided, in accordance with the Case Management Order and the Omnibus Claims Objection Procedures, to (a) each affected claimant set forth on the Proof of Claim and/or their respective attorney of record, as listed on Exhibits 1, 2 or 3 to the Proposed Order under the heading Claimant, (b) the U.S. Trustee, (c) counsel to the Committee Designee, Morrison & Foerster LLP, 250 West 55th Street, New York, New York 10019, Attn: Jonathan Levine, Esq. and Andrew Kissner, Esq. and (d) all parties on the Service List, as defined in the Case Management Order. 34. In light of the relief requested, the Reorganized Debtors submit that no other or further notice is necessary. No Prior Request 35. No prior request for the relief herein has been made to this or any other court. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] 12

16 Pg 16 of 43 Main Document WHEREFORE, the Reorganized Debtors respectfully request that the Bankruptcy Court enter an order, substantially in the form attached hereto as Exhibit A, granting the relief requested herein, and granting such other relief as is just and proper. Dated: New York, New York March 20, 2018 SULLIVAN & WORCESTER LLP By: /s/ Jeffrey R. Gleit Jeffrey R. Gleit, Esq. Allison H. Weiss, Esq Broadway New York, New York (212) (Telephone) (212) (Facsimile) Counsel for the Reorganized Debtors 13

17 Main Document Pg 17 of 43 Exhibit A Proposed Order

18 Pg 18 of 43 Main Document UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: 21st CENTURY ONCOLOGY HOLDINGS, INC., et al.,1 Reorganized Debtors. ) ) ) ) ) ) ) Chapter 11 Case No (RDD) (Jointly Administered) ORDER GRANTING REORGANIZED DEBTORS FIRST OMNIBUS OBJECTION TO CLAIMS SEEKING TO DISALLOW AND EXPUNGE (1) LATE FILED CLAIMS, (2) AMENDED AND SUPERSEDED CLAIMS AND (3) DUPLICATE CLAIMS Upon the First Omnibus Objection (Docket No. [ ]) (the First Omnibus Objection ) of the above-captioned reorganized debtors (collectively, the Reorganized Debtors and before the Effective Date of the Plan, the Debtors ), pursuant to sections 105(a) and 502(b) of title 11 of the United States Code (the Bankruptcy Code ), Rule 3007 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ), and the omnibus claims objection procedures (the Omnibus Claims Objection Procedures ), as approved by the Bankruptcy Court (defined herein) by that certain Order dated March 12, 2018 [Docket No. 1023] (the Omnibus Claims Objection Procedures Order ); and the Bankruptcy Court having jurisdiction to consider the Objection and the relief requested therein in accordance with 28 U.S.C. 157 and 1334 and the Amended Standing Order of Reference M-431, dated January 31, 2012 (Preska, C.J.); and consideration of the First Omnibus Objection and the relief requested therein being a core proceeding pursuant to 28 U.S.C. 157(b); and venue being proper before the Bankruptcy Court pursuant to 28 U.S.C and 1409; 1 Each of the Reorganized Debtors in the above-captioned jointly administered chapter 11 cases and their respective tax identification numbers are set forth in the Order Directing Joint Administration of Chapter 11 Cases [Docket No. 30]. The location of Holdings, Inc. s corporate headquarters and the Debtors service address is: 2270 Colonial Boulevard, Fort Myers, Florida

19 Main Document Pg 19 of 43 and due and proper notice of the First Omnibus Objection having been provided; and a hearing having been held on April 24, 2018 at 10:00 a.m. (Eastern Time) to consider the relief requested in the First Omnibus Objection (the Hearing ); and the record of the Hearing and all of the proceedings had before the Bankruptcy Court; and the Bankruptcy Court having found and determined that the relief sought in the First Omnibus Objection is in the best interests of the Reorganized Debtors, their estates, creditors, and all parties in interest, and that the legal and factual bases set forth in the First Omnibus Objection establish just cause for the relief granted herein; and after due deliberation and sufficient cause appearing therefor, it is ORDERED that the relief requested in the First Omnibus Objection is granted; and it is further ORDERED that, pursuant to section 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007, and the Omnibus Claims Objection Procedures, each of the claims listed on Exhibit 1 annexed hereto under the heading Claims (collectively, the Claims ) is disallowed and expunged; and it is further ORDERED that, pursuant to section 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007, and the Omnibus Claims Objection Procedures, each of the claims listed on Exhibit 2 annexed hereto under the heading Amended and Superseded Claims (collectively, the Amended and Superseded Claims ) is disallowed and expunged; and it is further ORDERED that, pursuant to section 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007, and the Omnibus Claims Objection Procedures, each of the claims 2

20 Main Document Pg 20 of 43 listed on Exhibit 3 annexed hereto under the heading Duplicate Claims (collectively, the Duplicate Claims ) is disallowed and expunged; and it is further ORDERED that nothing herein shall constitute an admission or finding with respect to the allowance, disallowance, validity or value of the Surviving A&S Claims (as defined in the First Omnibus objection) or the Surviving Duplicate Claims (as defined in the First Omnibus objection); and it is further ORDERED that this Order has no res judicata, estoppel, or other effect on the validity, allowance, or disallowance of, and all rights to object to or defend on any basis are expressly reserved with respect to any Claim, Amended and Superseded Claim, or Duplicate Claim referenced and/or identified in the First Omnibus Objection that is not listed on Exhibits 1, 2 or 3 annexed hereto; and it is further ORDERED that the Reorganized Debtors have reserved the right to later object to any Claim, Amended and Superseded Claim or Duplicate Claim to which the Bankruptcy Court does not grant the relief requested herein on any other basis. ORDERED that the Reorganized Debtors, the Reorganized Debtors Claims and Noticing Agent (Kurtzman Carson Consultants LLC), and the Clerk of this Bankruptcy Court are authorized to take all actions necessary or appropriate to give effect to this Order; and it is further ORDERED that this Bankruptcy Court shall retain jurisdiction over the Reorganized Debtors and the claimants whose claims are subject to the First Omnibus Objection with respect to any matters related to or arising from the First Omnibus Objection or the implementation of this Order. 3

21 Main Document Pg 21 of 43 Dated:, 2018 White Plains, New York THE HONORABLE ROBERT D. DRAIN UNITED STATES BANKRUPTCY JUDGE 4

22 Main Document Pg 22 of 43 Exhibit 1 Claims

23 Main Document Pg 23 of 43 Exhibit 1 # Name of Claimant Proof of Claim Late Claims to be Disallowed & Expunged Number Date Filed Asserted Claim Amount Debtor Name 1 A PLUS ENTERPRISES LLC /19/2017 $ AAA DEAF CORP /13/2017 $ ADELL, SUSAN /04/2017 $1, BARTLING, LAURA /11/2017 $ Blue Ridge X-ray Company, Inc /16/2017 $10, Bracco Diagnostics Inc /07/2017 $3, Caravetta, Sylvia /06/2017 $2,000, Carter, Tracy /07/2017 $100, CIC TECHNOLOGIES, INC /24/2018 $1, Administrative Reason for Disallowance Arizona Radiation Therapy Management Services, Administrative, LLC Administrative Administrative Administrative Administrative Administrative Administrative Administrative North Carolina Radiation Therapy Management Services, LLC Holdings, Holdings, Holdings, Holdings, Holdings, Holdings, In re Holdings, Inc., et al. Case No (RDD) Page 1 of 9

24 09/29/ Document Technologies LLC E&A CLEANING COMPANY Ellsworth, Robert C. Everett, Shirley FIRST FLORIDA INTEGRITY BANK Holdings, Inc. Administrative $1,000, In re Holdings, Inc., et al. Case No (RDD) Page 2 of 9 Proof of claim number 2548 can also be found listed on Exhibit 3 to the Propsosed Order (regarding Duplicate Claims)., LLC Holdings, Inc. Administrative $100, Administrative $159, Holdings, Inc. Administrative $538.45, Inc. Holdings, Inc. Administrative $ Administrative $7, Holdings, Inc. Reason for Disallowance Pg 24 of 43 09/29/ /06/ /07/ /25/2017, Inc. Administrative $2, Debtor Name Asserted Claim Amount Administrative $3, /12/ Diaz, Noelia 12 09/07/ De Guzman, Patricio G /14/ Date Filed CLIMATE CONTROL Name of Claimant 10 # Proof of Claim Number Late Claims to be Disallowed & Expunged Exhibit 1 Main Document

25 Main Document Pg 25 of 43 Exhibit 1 # Name of Claimant 18 Proof of Claim FIRST FLORIDA INTEGRITY BANK f/k/a FIRST NATIONAL BANK OF THE GULF COAST /29/2017 Late Claims to be Disallowed & Expunged Number Date Filed Asserted Claim Amount Debtor Name $108, Ganguli, Adwaita Kumar /11/2017 $ GARDINE-JEFFERSON, DESIREE /21/2017 $45, Goldman, Suzanne /18/2017 $ Hammonds, Timothy /08/2017 $ Hammonds, Timothy /17/ HARRIS BUSINESS MACHINES /18/2017 $ $ Hearst Television /21/2017 $12, Reason for Disallowance Administrative, LLC Administrative Administrative Administrative Administrative Administrative Holdings, Holdings, Holdings, Holdings, Holdings, $ Administrative, Administrative Holdings, 2 Asserted Claim amounts listed as $0.00 reflect that the Claim amount asserted on the Proof of Claim is unliquidated. In re Holdings, Inc., et al. Case No (RDD) Page 3 of 9

26 Main Document Pg 26 of 43 Exhibit 1 # Name of Claimant Proof of Claim Late Claims to be Disallowed & Expunged Number Date Filed Asserted Claim Amount Debtor Name 26 Jean, Richeline-Marie /20/2017 $3, JOHNSON, ANTWON /08/ Katzman, Stephanie M /26/2017 $1, Lamarca, Carson /16/2018 $2, Martin, Louis A and Norak Martin /13/2017 $ Matz, Harriet L /21/2017 $ Matz, Shari D /19/2017 $ MCCALLISTER, CHONG UN /19/2017 $ Administrative $ Administrative Administrative Administrative Administrative Administrative Administrative Administrative Reason for Disallowance Holdings, Holdings, Holdings, Holdings, Holdings, Holdings, South Florida Radiation Oncology, LLC Management Services, 2 Asserted Claim amounts listed as $0.00 reflect that the Claim amount asserted on the Proof of Claim is unliquidated. In re Holdings, Inc., et al. Case No (RDD) Page 4 of 9

27 Main Document Pg 27 of 43 Exhibit 1 # Name of Claimant Proof of Claim Late Claims to be Disallowed & Expunged Number Date Filed Asserted Claim Amount Debtor Name 34 Miller, Eugene /17/2017 $2, MILLS, KEISHA L /18/2017 $5, Modernizing Medicine, Inc /17/2017 $32, Mon Power /06/2017 $1, Mountain Valley Spring Water /12/2017 $2, Noll, Debra /19/2017 $1, Office Depot /10/2017 $5, Office Depot /23/2017 $5, Oliver, Willie /27/2017 Administrative Administrative Administrative Administrative Administrative Administrative Reason for Disallowance of Jacksonville, LLC Holdings, Holdings, Holdings, North Carolina Radiation Therapy Management Services, LLC of New Jersey, Administrative, Administrative, $2, Administrative Holdings, In re Holdings, Inc., et al. Case No (RDD) Page 5 of 9

28 Main Document Pg 28 of 43 Exhibit 1 # Name of Claimant Proof of Claim Late Claims to be Disallowed & Expunged Number Date Filed Asserted Claim Amount Debtor Name 43 Oncology Services International /12/2017 $5, Phoenix Management Company, LLC /11/2017 $6, Potomac Edison /06/2017 $4, Premier Pharmacy Labs Inc /18/ PROGRESS SOFTWARE CORP /09/2017 Reason for Disallowance Administrative, Administrative Administrative $2, Administrative $3, $3, Pure Water Partners /24/2018 $8, Pyne, Sean M /18/2017 $ $3, Rasberry, Sharmayne /06/2017 $7, Samol, Irene /19/2017 $ Administrative Administrative Administrative Phoenix Management Company, LLC Holdings, Services, LLC Management Services, Holdings, Holdings, Administrative, Administrative Holdings, In re Holdings, Inc., et al. Case No (RDD) Page 6 of 9

29 Scott, Thomas SHAH, SATISH Sneed, Jamie SSD SYSTEMS INC STITES & HARBISON, PLLC Tauriello, Gail /20/ /07/ /22/ /19/ /21/ /06/ /13/2017, Inc. Management Services, Inc. Holdings, Inc. Administrative $5, Administrative $2, Holdings, Inc. Gettysburg Radiation, LLC Holdings, Inc. In re Holdings, Inc., et al. Case No (RDD) Page 7 of 9 Holdings, Inc., LLC Reason for Disallowance Debtor Name Administrative $1, Administrative $10, Administrative $185, Administrative $1, $ Administrative Asserted Claim Amount Administrative $8, Pg 29 of 43 Proof of claim number 2548 can also be found listed on Exhibit 3 to the Propsosed Order (regarding Duplicate Claims) SC MEDICAL OVERSEAS INC ORFIT 53 11/20/2017 Date Filed Santee Cooper Name of Claimant 52 # Proof of Claim Number Late Claims to be Disallowed & Expunged Exhibit 1 Main Document

30 11/16/ TRANSYLVANIA COUNTY TAX TURNER, MARY Ultimate Water, LLC Ultimate Water, LLC Ultimate Water, LLC Financial Services Of Southwest Florida, LLC Holdings, Inc. Holdings, Inc. Holdings, Inc. Holdings, Inc. Holdings, Inc. Administrative $5, Administrative $6, Administrative $7, Administrative $1, Administrative $26, Administrative $ In re Holdings, Inc., et al. Case No (RDD) Page 8 of 9 Proof of claim number 2548 can also be found listed on Exhibit 3 to the Propsosed Order (regarding Duplicate Claims). Holdings, Inc. $2, Administrative $11, Pg 30 of 43 09/14/ /14/ /14/ /08/2017 Holdings, Inc. Reason for Disallowance Debtor Name Asserted Claim Amount $ Administrative 4 12/12/ Transunion Healthcare LLC 62 09/20/ TJL Information Technologies, Inc /27/ Date Filed The Street Art Loft Name of Claimant 60 # Proof of Claim Number Late Claims to be Disallowed & Expunged Exhibit 1 Main Document

31 Main Document Pg 31 of 43 Exhibit 1 # Name of Claimant Proof of Claim Late Claims to be Disallowed & Expunged Number Date Filed Asserted Claim Amount Debtor Name VANARSDALE INNOVATIVE PRODUCTS /03/2017 $10, VANGUARD CLEANING SYSTEMS OF LOUISVILLE /12/ VIAVID BROADCASTING CORP /18/2017 $1, VMG Health /15/2017 $26, Administrative $ Administrative Administrative Reason for Disallowance Holdings, Holdings, Management Services, Administrative, In re Holdings, Inc., et al. Case No (RDD) Page 9 of 9

32 Main Document Pg 32 of 43 Exhibit 2 Amended and Superseded Claims

33 Main Document Pg 33 of 43 Exhibit 2 # Name of Claimant Proof of Claim to be Disallowed or Expunged Surviving Proof of 1 Accuray Incorporated $640, Advanced Radiation Therapy LLC Amended and Superseded Claims Claim(s) Asserted Claim Amount Debtor Name Reason for Disallowance $ $16, Albion Staffing Solutions, Inc $22, Albion Staffing Solutions, Inc $22, Analogic Corporation $23, Analogic Corporation $17, Atlantic City Electric Company $2, Awotwi, Adwoa $65, BAMB, LLLP $391, Administrative, Inc. Amended and Superseded Administrative Administrative, Inc. Amended and Superseded Administrative, LLC Amended and Superseded Administrative Administrative Administrative Administrative, LLC Amended and Superseded Administrative In re Holdings, Inc., et al. Case No (RDD) Page 1 of 8

34 Main Document Pg 34 of 43 Exhibit 2 # Name of Claimant Proof of Claim to be Disallowed or Expunged Surviving Proof of Amended and Superseded Claims 10 Bayer HealthCare $5, Biotechnology Integration And Management LLC $33, BlueNET Technologies Inc $12, CANCER CARE CENTER PROPERTY MGMT Cancer Treatment Services International - Arizona, LLC $3,534, Cancer Treatment Services International - Arizona, LLC $3,534, Cogentix Medical $34, Cogentix Medical CRYOTECH SERVICES LLC $23, Claim(s) Asserted Claim Amount Debtor Name Reason for Disallowance Administrative, Inc. Amended and Superseded Administrative Administrative Management Services, Inc. Amended and Superseded Management Services, Inc. Amended and Superseded $2, Administrative, LLC Amended and Superseded Administrative, Inc. Amended and Superseded Administrative Administrative Arizona Radiation Therapy Management Services, Inc. Amended and Superseded $16, Administrative, LLC Amended and Superseded Administrative In re Holdings, Inc., et al. Case No (RDD) Page 2 of 8

35 Main Document Pg 35 of 43 Exhibit 2 # Name of Claimant Proof of Claim to be Disallowed or Expunged Surviving Proof of Department of the Treasury - Internal Revenue Service Amended and Superseded Claims Claim(s) Asserted Claim Amount Debtor Name Reason for Disallowance $ $12, DOC-21ST CENTURY SARASOTA, LLC/PHYSICIANS REALTY L.P $ DOC-21ST CENTURY SARASOTA, LLC/PHYSICIANS REALTY L.P $ DOC-21ST CENTURY SARASOTA, LLC/PHYSICIANS REALTY L.P $ Dura-Shine Clean, LLC $1, eclinicalworks, LLC $1, Extropy, LLC $12, $ Fantazzp, Robin $ Flatiron Health Inc $11.58 Administrative Associates in Radiation Oncology Services, LLC Amended and Superseded Administrative, Inc. Amended and Superseded Administrative, LLC Amended and Superseded Administrative U.S. Cancer Care, Inc. Amended and Superseded Administrative Administrative Administrative, Inc. Amended and Superseded Administrative Administrative, LLC Amended and Superseded 1 Asserted Claim amounts listed as $0.00 reflect that the Claim amount asserted on the Proof of Claim is unliquidated. In re Holdings, Inc., et al. Case No (RDD) Page 3 of 8

36 Main Document Pg 36 of 43 Exhibit 2 # Name of Claimant Proof of Claim to be Disallowed or Expunged Surviving Proof of 28 Ikonisys, Inc Indian River County Tax Collector Amended and Superseded Claims Claim(s) Asserted Claim Amount Debtor Name Reason for Disallowance $23, Administrative $10, JRE Enterprises Of Casa Grande, LLC $3,450, K S Associates Inc LEE COUNTY TAX COLLECTOR LEE COUNTY TAX COLLECTOR Administrative Administrative, Inc. Amended and Superseded $21, Administrative $14, $8, Level 3 Telecom Holdings, LLC f/k/a TW Telecom Holdings Inc $42, MEDICAL SPECIALTIES DISTRIBUTIONS LLC $9, Modernizing Medicine, Inc $32, Administrative Administrative Administrative Administrative Administrative Financial Services Of Southwest Florida, LLC Amended and Superseded In re Holdings, Inc., et al. Case No (RDD) Page 4 of 8

37 Main Document Pg 37 of 43 Exhibit 2 # Name of Claimant Proof of Claim to be Disallowed or Expunged Surviving Proof of Amended and Superseded Claims 37 Napier, Elizabeth $ NBC Universal Media LLC $19, Okaloosa County Tax Collector Claim(s) Asserted Claim Amount Debtor Name Reason for Disallowance $19, Oliver Wyman Actuarial Consulting, Inc $94, Oneupweb 6 83 $17, PE Facility Solutions LLC $12, Precision Air Systems Inc $2, Proclean Authority, Inc $26, Protransportation Inc $50, Administrative Administrative Administrative Administrative South Florida Radiation Oncology, LLC Amended and Superseded Administrative, Inc. Amended and Superseded Administrative Administrative Administrative Administrative 1 Asserted Claim amounts listed as $0.00 reflect that the Claim amount asserted on the Proof of Claim is unliquidated. In re Holdings, Inc., et al. Case No (RDD) Page 5 of 8

38 Main Document Pg 38 of 43 Exhibit 2 # Name of Claimant 46 Proof of Claim to be Disallowed or Expunged Surviving Proof of Amended and Superseded Claims Regional Care Health Ventures, Inc $300, Riccardo, Toni L $ Sasso Air Conditioning, Inc. dba EDS Air Conditioning $18, Seaside National Bank and Trust ; 1212 $1,427, Seaside National Bank and Trust $1,427, Seaside National Bank and Trust $1,427, Seaside National Bank and Trust $1,427, Seaside National Bank and Trust $1,427, Soliant Health $208, Claim(s) Asserted Claim Amount Debtor Name Reason for Disallowance Administrative Arizona Radiation Therapy Management Services, Inc. Amended and Superseded Administrative, LLC Amended and Superseded Administrative Administrative Associates in Radiation Oncology Services, LLC Amended and Superseded Administrative Treasure Coast Medicine, LLC Amended and Superseded Administrative South Florida Radiation Oncology, LLC Amended and Superseded Administrative SFRO Holdings, LLC Amended and Superseded Administrative Boynton Beach Radiation Oncology, L.L.C. Amended and Superseded Administrative, Inc. Amended and Superseded 1 Asserted Claim amounts listed as $0.00 reflect that the Claim amount asserted on the Proof of Claim is unliquidated. In re Holdings, Inc., et al. Case No (RDD) Page 6 of 8

39 Main Document Pg 39 of 43 Exhibit 2 # Name of Claimant Proof of Claim to be Disallowed or Expunged Surviving Proof of 55 SRS Medical Systems, Inc Amended and Superseded Claims Claim(s) Asserted Claim Amount Debtor Name Reason for Disallowance $15, $22, Stratus Technologies, Inc $58, SYRACUSE MEDICAL DEVICES INC Tax Compliance, Inc TERRYBERRY COMPANY LLC $4, TERRYBERRY COMPANY LLC $5, The Inside Corner, Inc $7, The University of Texas M.D. Anderson Cancer Center - RDS $22, Theriac Enterprises of Harrington, LLC $16, Administrative Administrative U.S. Cancer Care, Inc. Amended and Superseded $ Administrative U.S. Cancer Care, Inc. Amended and Superseded $32, Administrative Administrative Administrative Administrative Administrative Radiation Therapy Services International, Inc. Amended and Superseded Administrative, Inc. Amended and Superseded In re Holdings, Inc., et al. Case No (RDD) Page 7 of 8

40 Main Document Pg 40 of 43 Exhibit 2 # Name of Claimant Proof of Claim to be Disallowed or Expunged Surviving Proof of Amended and Superseded Claims UnitedHealthcare Insurance Company $352, UnitedHealthcare Insurance Company ; 2638 Claim(s) Asserted Claim Amount Debtor Name Reason for Disallowance $ $6,225, Walters Levine and Lozano $236, Windstream $70, Administrative, LLC Amended and Superseded Administrative, LLC Amended and Superseded Administrative Administrative Financial Services Of Southwest Florida, LLC Amended and Superseded 1 Asserted Claim amounts listed as $0.00 reflect that the Claim amount asserted on the Proof of Claim is unliquidated. In re Holdings, Inc., et al. Case No (RDD) Page 8 of 8

41 Main Document Pg 41 of 43 Exhibit 3 Duplicate Claims

42 County of San Bernardino Dignity Health E&A CLEANING COMPANY Franchise Tax Board Guardian Protection Services Palm Beach County Holdings, Inc. Administrative $3, Holdings, Inc. Administrative $ In re Holdings, Inc., et al. Case No (RDD) Page 1 of 2, LLC U.S. Cancer Care, Inc. Administrative $3, $ Administrative $35.00 Holdings, Inc. Administrative $ California Radiation Therapy Management Services, Inc. Holdings, Inc. Administrative $56, $ Holdings, Inc. Administrative $ Administrative Holdings, Inc. Asserted Claim amounts listed as $0.00 reflect that the Claim amount asserted on the Proof of Claim is unliquidated. Proof of claim number 2548 can also be found listed on Exhibit 1 to the Proposed Order (regarding Claims). COLLIER COUNTY TAX COLLECTOR Debtor Name Administrative $6, Asserted Claim Amount Duplicate Claim Duplicate Claim Duplicate Claim Duplicate Claim Duplicate Claim Duplicate Claim Duplicate Claim Duplicate Claim Duplicate Claim Reason for Disallowance Pg 42 of 43 2 CODA Link, Inc Surviving Proof of Claim 1 Alin, Patricia Name of Claimant 1 # Proof of Claim Number to be Disallowed Duplicate Claims Exhibit 3 Main Document