This Action arises from the Defendant’s breach of its confirmed chapter 11 bankruptcy plan of reorganization. In exchange for broad general releases of Defendant, its management and others contained in Defendant’s bankruptcy plan (which called for cancellation of existing equity interests in Defendant (defined by the Plan as “Unit Corp. Interests”), Defendant agreed to issue to holders of Unit Corp. Interests warrants to purchase new common stock to be issued under Defendant’s bankruptcy plan.