LAMAR DAVIS, Bankruptcy Judge
WHEREAS, JPMorgan Chase Bank ("JPMorgan") filed a proof of claim (the "Proof of Claim") against Durango Georgia Paper Company (the "Debtor") in the above-captioned cases, asserting a claim against the Debtor in the amount of $4,985,268.45 plus interest, commissions, fees, costs, and expenses (collectively, "Costs and Expenses") arising from (i) the Standby or Performance Letter of Credit Application and Agreement, executed as of March 14, 2000 by the Debtor as Account Party in favor of JPMorgan in respect of the Irrevocable Standby Letter of Credit, bearing reference number P-298825, and issued in the aggregate amount of $3,117,216.29, for the benefit of Pitney Bowes Credit Corporation; and (ii) the Standby or Performance Letter of Credit Application and Agreement, executed as of April 19, 2000 by the Debtor as Account Party in favor of JPMorgan in respect of the Irrevocable Standby Letter of Credit, bearing reference number P-200159, and issued in the aggregate amount of $2,615,723.00, for the benefit of SunTrust Leasing Corporation;
WHEREAS, the Debtor filed its First Omnibus Objection of Debtors to Claims (the "Claims Objection") on June 26, 2003, and objected to the Proof of Claim on the ground that the Proof of Claim should be disallowed as untimely and should not have been filed as a secured claim;
WHEREAS, JPMorgan has explained its position to counsel for the Debtor and counsel for the Committee of Unsecured Creditors (the "Committee") that its Proof of Claim was properly filed as a secured claim and that JPMorgan's Proof of Claim cannot be deemed untimely because JPMorgan was not listed on the creditor matrix in these cases, was not provided with notices of these cases or of the claims bar date and because the Debtor was aware of the liabilities to JPMorgan underlying the Proof of Claim;
WHEREAS, without waiving any other rights or obligation imposed by applicable law or contract, JPMorgan has agreed to comply in good faith with any document subpoena or request for production served in these cases by counsel for Debtors or the Committee and has agreed not to challenge any such subpoena on jurisdictional grounds;
WHEREAS, JPMorgan agrees to properly authenticate any and all documents responsive to such subpoena or discovery request;
WHEREAS, the Debtor, the Committee, and JPMorgan have agreed, subject to Court approval, to resolve the Claims Objection relative to JPMorgan's Proof of Claim on the terms set forth herein;
WHEREAS, it is in the best interest of the estates and the Debtors to resolve this matter; and
THEREFORE, the Debtors, the Committee, and JP Morgan hereby agree and stipulate, and it is ordered, adjudged and decreed, that:
1. The Recitals contained hereinabove are incorporated herein by this express reference;
2. JPMorgan's Proof of Claim shall be and hereby is deemed to have been timely filed;
3. JPMorgan's Proof of Claim shall be and hereby is reclassified as a general unsecured claim; and
4. Any and all objections that were or could have been asserted by or on behalf of the Debtors and by or on behalf of the Committee against JPMorgan in connection with the timeliness of the filing of the Proof of Claim are hereby withdrawn, waived, released, and dismissed.