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But entering bankruptcy posed a unique set of problems: Old GM sought to restructure and become profitable again, not to shut down; yet if Old GM lingered in bankruptcy too long, operating expenses would accumulate and consumer confidence in the GM brand could deteriorate, leaving Old GM no alternative but to liquidate and close once and for all. See, e.g., In re Lionel Corp., 722 F.2d 1063, 1066-70 (2d Cir. The usual Chapter 11 reorganization follows set procedures: the company entering bankruptcy (the “debtor”) files a reorganization plan disclosing to creditors how they will be treated, asks those creditors to vote to accept the plan, and then emerges from bankruptcy with its liabilities restructured along certain parameters. The Sale Agreement also imposed an “accordion feature” to ensure that GUC Trust would remain adequately funded in the event that the amount of unsecured claims grew too large. On March 29, 2011, the bankruptcy court confirmed this liquidation plan. 137, 151 (2009); see Millenium Seacarriers, 419 F.3d at 96 (“A bankruptcy court retains post-confirmation jurisdiction to interpret and enforce its own orders, particularly when disputes arise over a bankruptcy plan of reorganization.” (quoting Petrie Retail, 304 F.3d at 230)). The bankruptcy court first interpreted the “free and clear” provision that barred successor liability claims—a provision that was integral to resolving Old GM's bankruptcy—and then determined whether to enforce that provision Second, the Non-Ignition Switch Plaintiffs specify that the bankruptcy court lacked jurisdiction over independent claims. By making the argument that the bankruptcy court could not enjoin independent claims through the Sale Order, the Non-Ignition Switch Plaintiffs already assume that the bankruptcy court indeed has jurisdiction to interpret the Sale Order to determine whether it covers independent claims and to hear a motion to enforce in the first place. See Chateaugay I, 944 F.2d at 1003-04 (calling such a reading “absurd”). Indeed, by filing a motion to enforce, New GM in effect asked for the courts to interpret the Sale Order. In sum, the “free and clear” provision covers pre-closing accident claims and economic loss claims based on the ignition switch and other defects. ...

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