They don't need to counter.

Noteholders can hold out and not affirm the Plan of Compromise/Arrangement.

The judge can do many things, but cannot force how they vote.

Stalemate will mean they can leverage the Plan of Compromise/Arrangement to include being paid off. The PP re-enters. Noteholders happily leave this nightmare, as many here would also like to do.

Because of the lack of motion materials disclosure on the E&Y site, at may already be cinched up.