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6.

As to components (b) through (e) of the Claim, I assert that Shakur has not

2 made a prima face case and Shakur is, indeed, agreeing to their disallowance in their entirety. 3 However, as a compromise, I agree to the allowance of one component of the Claim, component 4 a relating to the final arbitration award. Absent this compromise, I am informed and believe that 5 litigation would proceed on all five components of the Claim, each of which involves factual and 6 legal issues. I am well aware that there are costs and risks always attendant to litigation. Given the 7 number of legal and factual issues, I am informed and believe that litigation, including discovery, 8 could be extensive. 9 7. The Settlement Agreement proposed herein would benefit the Consolidated Estates

10 creditors because it reduces a claim of $2,218,121.76, by nearly 70% to $668,121.76. I have 11 obtained the disallowance of four out of five of the components of Shakurs Claim while agreeing 12 to the allowance of the stronger fifth component. I conclude based on my experience and business 13 judgment that, ultimately, this compromise results in a substantial benefit to the remaining 14 unsecured creditors, treats the Claimant fairly, and succeeds in avoiding the undue risk and expense 15 of further litigation. I believe that extensive litigation which would likely be necessary in this 16 proceeding does not appear to be economically warranted in light the projected magnitude of 17 distributions to allowed general unsecured claims. 18 19 I declare under penalty of perjury under the laws of the United States of America that the

20 foregoing is true and correct. 21 22 23 R. TODD NEILSON 24 25 26 27 28

1016185.1 25382

Executed June ____, 2013, at Los Angeles, California.

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