Here are some excerpts from the Special Master's response. I don't think he has control of any of this which is surprising that he doesn't punt and allow the court to reply.   

Also, not surprisingly, the Venezuela Sale's Parties objected to all of this.

I know this doesn't pertain to KRY specifically but I know others - including myself - have positions in some of the other Six Creditors.                              

                                    ARGUMENT

A. The Special Master Takes No Position With Respect To Application Of The Sale Procedures Order In The Actions Of The Six Creditors

The Special Master was appointed by the Court, pursuant to its Memorandum Order dated

April 13, 2021 (D.I. 258), to assist with the sale of the PDVH Shares in satisfaction of the

Crystallex judgment in the instant matter. The Special Master’s mandate and authority does not

currently extend to the proceedings of the Six Creditors. As such, the Special Master shall not at

this time expound on the reasons for or against applying the Sale Procedures Order beyond the

Crystallex matter. If the Court were to dismiss the Crystallex matter for any reason, and the Court

directs the Special Master to continue the sale process under a different case, he will do so.

B. The Six Creditors Should Be Designated As Additional Judgment Creditors

The Six Creditors argue that their immediate designation as Additional Judgment Creditors

“would sufficiently protect the sale process because Additional Judgment Creditors have rights

under both the order appoints the Special Master and the [Sale Procedures Order].” 

Without opining on whether the action of naming Additional Judgment Creditors alone would

ensure the continuation of the sale process beyond a hypothetical dismissal of the Crystallex case,

the Special Master agrees the Six Creditors (among others) should be immediately designated

as Additional Judgment Creditors.

The Special Master has already recommended that all parties included in the Steps Chart

filed on November 15, 2023 be named Additional Judgment Creditors.

C. Immediate Perfection Of The Six Creditors’ Judgments Will Jeopardize The Court’s Carefully Constructed Priority Determination Scheme

Lastly, the Six Creditors invite the Court to fashion an alternative remedy, including to

“implement the perfection process immediately in accordance with the Court’s priority scheme.”

The Special Master strongly believes the Court should decline this invitation.

Granting the Six Creditors immediate leave to perfect their judgments would defeat the

carefully constructed priority perfection process set forth in the Court’s July 27, 2023 Memorandum

Order  and October 11, 2023 Memorandum Order...

Any unnecessary change to that process at this stage

could disrupt the proper arrangement of priority. Accordingly, the Court should deny the Six

Creditors’ Motion to the extent they seek immediate perfection of their judgments.