In addition, your Applicant immediately began examining and evaluating the Debtor’s assets, liabilities and transactions. Your Applicant has endeavored to obtain documents and financial data from the Debtor and affiliated parties. Because the Debtor represented that information requested by the Committee is confidential, your Applicant negotiated and drafted a non-disclosure agreement with the Debtor to gain access to such data and documentation. However, due to the incomplete, inconsistent and even non-existent nature of many of the documents obtained or requested by your Applicant, your Applicant has been required to engage in an often cumbersome exercise to evaluate various documents including license agreements, employment agreements, service agreements and other executory contracts, in addition to the Debtor’s explanations and representations regarding such documents.

How many executory contracts are out there? These unsecured debtors are doing what PTSC should have been doing along time ago. The onion is being peeled.