Post on 02-Apr-2018
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7/27/2019 Amaru Settlement for 30 cents on the dollar.
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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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