Exhibit 99.1

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE

CERTIFICATION OF COUNSEL REGARDING

FINAL CASH COLLATERAL ORDER AND BUDGET

The undersigned, counsel to the debtors and debtors-in-possession in the above-

captioned cases (the “Debtors”), hereby certifies as follows:

On October 14, 2013, the Debtors filed the Debtors’ Motion For Interim And

Final Orders Under 11 U.S.C. §§ 105, 361, 362, 363, 507(b), Fed. R. Bankr. P. 4001, 6004(h),

7062 And 9014 And Del. Bankr. L.R. 4001-2 (I) Authorizing The Debtors To Use Cash

Collateral, (II) Granting Adequate Protection To Prepetition Secured Noteholders, And

(III) Scheduling Final Hearing Pursuant To Fed. R. Bankr. P. 4001(B) [Docket No. 16] (the

“Motion”).

On October 16, 2013, United States Bankruptcy Court for the District of

Delaware (the “Bankruptcy Court”) entered the Interim Order Under 11 U.S.C. §§ 105, 361, 362,

363, 507(b), Fed. R. Bankr. P. 4001, 6004(h), 7062, And 9014 And Del. Bankr. L.R. 4001-2

(I) Authorizing The Debtors To Use Cash Collateral, (II) Granting Adequate Protection to

Prepetition Secured Noteholders, (III) Scheduling a Final Hearing Pursuant to Fed. R. Bankr. P.

4001(B), and (IV) Granting Related Relief [Docket No. 43] (the “Interim Order”).

On December 13, 2013, the Bankruptcy Court entered the Final Provisional Order

Under 11 U.S.C. §§ 105, 361, 362, 363, 507(b), Fed. R. Bankr. P. 4001, 6004(h), 7062, And

9014 And Del. Bankr. L.R. 4001-2 (I) Authorizing The Debtors To Use Cash Collateral,

(II) Granting Adequate Protection To Prepetition Secured Noteholders, And (III) Granting

Related Relief [Docket No. 250] (the “Final Provisional Order”).²

The Final Provisional Order provided that any party in interest objecting to the

entry of such order was required to file and serve a written objection by December 27, 2013. No

objection to entry of the Final Provisional Order was filed or served.

The Final Provisional Order did not attach a final cash collateral Budget. Rather,

the order provided that “[d]uring the period from December 13, 2013 to December 20, 2013, the

Parties shall roll forward the existing Budget which shall be deemed adjusted to increase the 13-

week cash and accrual line items consistent with previous weeks to account for the later than

anticipated closing of the Sale and the fees and costs resulting therefrom and shall work in good

faith with regard to certain line items in the Budget.” Final Provisional Order at ¶ 18(d), fn. 4.

On December 30, 2013, the Debtors filed the Notice Of Filing Of Current

Working Draft Of Cash Collateral Budget And Illustrative Sources And Uses [Docket No. 295],

which notice attached, among other things, a working draft of the cash collateral Budget.

The Debtors, the Unofficial Committee of Senior Secured Noteholders and the

Committee have negotiated in good faith and agreed on the final form of cash collateral Budget.

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Attached hereto are the final forms of the 13-Week Budget (Exhibit A) and Accrual Budget (Exhibit A-1).

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EXHIBIT A

13-Week Budget

EXHIBIT A: 13-WEEK BUDGET

(a) Amounts shown in weeks ending 12/27/13, 1/3/14 and 1/10/14 are estimates for all remaining disbursements to be made before and after assumed closing date (estimated on 1/10/14).

EXHIBIT A-1

Accrual Budget

EXHIBIT A-1: ACCRUAL BUDGET