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<br />described in Section 11.4(b) of the Plan, shall in consideration for the obligations of the Debtors and the
<br />Reorganized Debtors under the Plan and the securities, contracts, instruments, releases and other
<br />agreements or documents to be delivered in connection with the Plan, forever release, waive and
<br />discharge all claims, obligations, suits, judgments, damages, demands, debts, rights, causes of action and
<br />liabilities (other than the rights to enforce the Debtors' or the Reorganized Debtors' obligations under
<br />the Plan and the securities, contracts, instruments, releases and other agreements and documents
<br />delivered thereunder), whether liquidated or unliquidated, fixed or contingent, matured or unmatured,
<br />known or unknown, foreseen or unforeseen, then existing or thereafter arising, in law, equity or
<br />otherwise that are based in whole or in part on any act, omission, transaction, event or other occurrence
<br />taking place on or prior to the Effective Date in any way relating to the Debtors, the Reorganized
<br />Debtors, the Chapter 11 Cases or the conduct thereof, or this Plan against: (i) the Debtors; (ii) the
<br />Reorganized Debtors; and (iii) the Released Parties.
<br />14. Exculpation and Limitation of Liability Regarding Conduct of Chapter 11 Cases. The
<br />Debtors, the Reorganized Debtors, the Statutory Committees, the members of the Statutory Committees
<br />in their capacities as such, the DIP Lenders, the DIP Agent, the Prepetition Agent, the Prepetition
<br />Lenders, the Indenture Trustees, each holder of the AREC Notes, SAC Holding, Bank of Montreal in its
<br />capacity as administrative agent for the lenders under the BMO Master Lease, and each of the financial
<br />institutions party to the BMO Master Lease (collectively, the "BMO Lease Parties "), BMO Global
<br />Solutions, Inc., in its capacity as agent lessor under the BMO Master Lease and the Citibank Master
<br />Lease, Citicorp USA, Inc., in its capacity as agent under the Citibank Master Lease, and each of the
<br />financial institutions party to the Citibank Master Lease (collectively, the "Citibank Lease Parties "),
<br />and each such parties' respective professionals, agents, present or former members, officers and
<br />directors and any of such parties' successors and assigns, shall not have or incur, and are hereby forever
<br />270895.5
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