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Recovery at default time is different than at bankruptcy exit time. Sometimes vastly different, as for Delphi (DPHIQ.PK).

In 2005, when Delphi went bankrupt, there was some fear of a short squeeze in the underlying bonds as the number of outstanding CDSs was 12 times that of the underlying bonds. An auction was held to help get a cash settlement for excess CDSs.

Recovery price: 63.375
Delphi is having some difficulty getting out of bankruptcy and current recovery is estimated at around 32.000.
With the benefit of hindsight, paying cash instead of taking bonds was a very clever or lucky move.

Sources:

Delphi Auction Results
Delphi May Require GM Financing for Bankruptcy Exit
Meter still running on GM’s Delphi ride