EXHIBIT A 

Scope Division Among Official Committee of Tort Claimants’ Financial Advisors 

Lincoln DSI 

Review and analyze the Debtors’ operations and businesses 

and financial projections, including but not limited to, 

financial condition, business plan strategy, operating 

forecasts, cash flow projections, and budgets. 

Advising the TCC and Counsel regarding the tort claims 

process, filing and processing of tort claims and estimation 

of tort claims. 

Review, analyze and monitor DIP financing and other 

financing alternatives. 

Claims Management including establishing procedures for 

claims processing and coordination with claimants. 

Assist with the review and calculation(s) of the cost/benefit 

analysis with respect to the affirmation or rejection of any 

executory contracts (including, but not limited to, power 

purchase agreements) 

In connection with the estimation of tort claims and claimsrelated issues, advise the TCC with respect to formulation 

of a plan and disclosure statement provisions as well as 

plan feasibility that involve the foregoing. 

Analyze proposed sale(s) of core / non-core assets of the 

Debtors, the terms thereof and options and issues relating 

thereto, including strategic alternatives available to the 

Debtors. 

Participate in meetings / calls with the Debtors, creditors, 

other committees, the U.S. Trustee, and other parties in 

interest and professionals hired by the same, as requested. 

Determine a theoretical range of values for the Debtors on 

a going concern basis as well as any securities to be issued 

or distributed in connection with the Chapter 11 Cases, 

including without limitation any securities to be distributed 

under a plan of reorganization. 

Perform such other tasks as may be agreed to by DSI and 

directed by the TCC or order of the Court having 

jurisdiction over the TCC 

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Scope Division Among Official Committee of Tort Claimants’ Financial Advisors 

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Assist the TCC in developing, evaluating, structuring and 

negotiating the terms and conditions of a restructuring, 

plan of reorganization, disclosure statement, or sale 

transaction(s), including the value of the securities, if any, 

that may be issued to the TCC under any such 

restructuring, plan of reorganization, or sale transaction. 

Assist the TCC with its communications website as 

required by Section 1102 of the Bankruptcy Code. 

Analyze any new debt or equity capital (including advice 

on the nature and terms of new securities). 

Provide analysis on illustrative claim recoveries. 

Assist the TCC in responses / objections to Bankruptcy 

Court motions. 

Attend meetings and assist in discussions with the Debtors, 

secured and unsecured creditors, other Official 

Committee(s), the U.S. Trustee, other parties in interest and 

professionals hired by the same, as requested. 

Assist the TCC in negotiations with all case participants 

(including, but not limited to, Debtors, secured and 

unsecured creditors, other Official Committee(s), State of 

California, California Public Utilities Commission, power 

purchase agreements, among other parties), as requested. 

If requested by the legal counsel to the TCC, prepare 

report(s) with respect to any and all proposed financings, 

the valuation of the company (as a going concern or 

otherwise), or proposed merger, divestiture, joint-venture, 

or investment transaction. 

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Scope Division Among Official Committee of Tort Claimants’ Financial Advisors 

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Provide testimony in connection with Lincoln Advisors’ 

provision of any of the above-mentioned services in the 

Bankruptcy Court or other court. 

Render such other general investment banking or financial 

advisory assistance as the TCC may reasonably request that 

is consistent with the role of Lincoln Advisors’ role 

financial advisor(s) and not duplicative of services 

provided by other professionals retained by the TCC. 

Review and advise on the Debtors’ real estate portfolio and 

evaluate leases for optimization/rejection and any proposed 

real estate sales or financings. 

Assist counsel with advising the TCC on tax issues relating 

to the Debtors. 

Monitor the Debtors’ liquidity including evaluation of 

critical vendor payments and other key payments. 

Review of statements of financial affairs, schedules of 

assets and liabilities and related documents and report to 

the TCC as appropriate. 

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