18. The OCC consciously elected to disregard the Settlement Procedure Order for
improper purposes. The OCC freely admits in the Motion why it did so, and the timing of that
admission is as damning as its substance. The OCC advised TPL on November 13, 2013, that “ .
..... "without significant progress in the negotiations regarding the plan, you should not expect
approval of further proposed licensing transactions/settlements.�.....