Case: HJB Doc #: 3074 Filed: 02/08/16 Desc: Main Document Page 1 of 7 UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW HAMPSHIRE : :

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1 Case HJB Doc # 3074 Filed 02/08/16 Desc Main Document Page 1 of 7 HEARING DATE AND TIME April 14, 2016 at 1000 a.m. (Eastern Time) OBJECTION DEADLINE February 29, 2016 at 400 p.m. (Eastern Time) UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW HAMPSHIRE x In re GT ADVANCED TECHNOLOGIES INC., et al., Debtors x Chapter 11 Case No HJB Jointly Administered DEBTORS FOURTEENTH OMNIBUS OBJECTION TO CLAIMS (RECLASSIFIED AND MODIFIED CLAIMS; NO LIABILITY CLAIMS) GT Advanced Technologies Inc. and its affiliated debtors as debtors in possession (collectively, GTAT or the Debtors ), pursuant to section 502 of title 11 of the United States Code (the Bankruptcy Code ) and Rule 3007 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ), file this fourteenth omnibus objection (the Objection ) to those claims listed on Schedules 1 and 2 to the attached proposed order. In further support of the Objection, the Debtors respectfully represent as follows JURISDICTION 1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and This matter is a core proceeding within the meaning of 28 U.S.C. 157(b)(2). Venue is proper pursuant to 28 U.S.C and The Debtors in these chapter 11 cases, along with the last four digits of each debtor s tax identification number, as applicable, are GT Advanced Technologies Inc. (6749), GTAT Corporation (1760), GT Advanced Equipment Holding LLC (8329), GT Equipment Holdings, Inc. (0040), Lindbergh Acquisition Corp. (5073), GT Sapphire Systems Holding LLC (4417), GT Advanced Cz LLC (9815), GT Sapphire Systems Group LLC (5126), and GT Advanced Technologies Limited (1721). The Debtors corporate headquarters are located at 243 Daniel Webster Highway, Merrimack, NH

2 Case HJB Doc # 3074 Filed 02/08/16 Desc Main Document Page 2 of 7 2. The statutory bases for the relief requested herein are section 502 of the Bankruptcy Code and Bankruptcy Rule BACKGROUND 3. On October 6, 2014 (the Petition Date ), the Debtors filed voluntary cases under chapter 11 of the Bankruptcy Code in the United States Bankruptcy Court for the District of New Hampshire (the Court ). The Debtors continue to operate their businesses and manage their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No request for the appointment of an examiner has been made in these chapter 11 cases. A motion to appoint a trustee has been denied. 4. On October 14, 2014, the Office of the United States Trustee for the District of New Hampshire appointed an official committee of unsecured creditors (the Committee ) to these chapter 11 cases pursuant to section 1102(a)(1) of the Bankruptcy Code [Docket No. 127]. 5. These chapter 11 cases have been consolidated for procedural purposes only and jointly administered pursuant to Bankruptcy Rule 1015(b). Claims Bar Date and Schedules 6. On October 30, 2014, the Court entered the Order, Pursuant to Bankruptcy Code Sections 105(a), 501, 502(b)(9), and 503, Bankruptcy Rules 2002(l) and 3003(c)(3), and LBR (b), (A) Establishing Bar Date for Filing of Proofs of Claim, (B) Designating Form and Manner of Notice Thereof, and (C) Granting Related Relief [Docket No. 395] (the Bar Date Order ). The Debtors filed their schedules of assets and liabilities and their statements of financial affairs on November 21, On November 26, 2015, the Debtors filed the Notice of Bar Dates for Filing Proofs of Claim [Docket No. 629], which established January 26, 2015, at 500 p.m. (prevailing Eastern Time) as the general deadline to file proofs of claim (the Bar 2

3 Case HJB Doc # 3074 Filed 02/08/16 Desc Main Document Page 3 of 7 Date ) against the Debtors in these chapter 11 cases by creditors other than governmental units. 2 Pursuant to the Bar Date Order, each creditor, subject to certain limited exceptions, was required to file a proof of claim on or before the Bar Date. 7. In accordance with the Bar Date Order, Kurtzman Carson Consultants LLC ( KCC ), the Debtors court-appointed notice and claims agent, mailed notices of the Bar Date and proof of claim forms to, among others, all of the Debtors creditors and other known potential holders of claims as of the Petition Date. Notice of the Bar Date also was published in The New York Times on December 1, On August 24, 2015, the Court entered the Order Pursuant to Section 105(a) of the Bankruptcy Code and Bankruptcy Rule 3007 Approving Claims Objection Procedures [Docket No. 2213] (the Claims Procedures Order ), which set forth the procedures to file omnibus claims objections. Proofs of Claim 9. More than 1,050 proofs of claim have been filed in these chapter 11 cases. The Debtors are in the process of reviewing and reconciling the filed proofs of claim. This process includes identifying particular categories of claims that may be targeted for reclassification and/or modification or disallowance and expungement. To avoid possible double recovery or improper recovery by claimants, the Debtors anticipate filing objections to these categories of claims. This is one such objection. 10. As part of their ongoing review, the Debtors have reviewed the proofs of claim listed on Schedules 1 and 2 to the attached proposed order and have concluded that each such claim appropriately is objected to on the basis set forth below. 2 The Bar Date Order also established a deadline of April 6, 2015 for governmental units to file proofs of claim. 3

4 Case HJB Doc # 3074 Filed 02/08/16 Desc Main Document Page 4 of 7 RELIEF REQUESTED 11. By this Objection, the Debtors seek entry of an order, pursuant to section 502(b) of the Bankruptcy Code and Bankruptcy Rule 3007 (i) reclassifying and/or modifying the claims listed on Schedule 1 to the attached proposed order; and (ii) disallowing and expunging the claims listed on Schedule 2 to the attached proposed order. OBJECTION TO CLAIMS A. Reclassified and Modified Claims 12. The Debtors object to the claims listed in Schedule 1 to the attached proposed order because the Debtors books and records show that the Debtors are not liable for the full amount alleged in each claim. Accordingly, the Debtors request an order modifying these claims by reducing the amount of each claim as set forth in Schedule The Debtors object to Claim No. 881, listed in Schedule 1 to the attached proposed order, on the grounds that it is improperly alleged to be a secured claim. The claimant that filed Claim No. 881 asserted reclamation and stoppage rights with respect to goods it alleges to have sold to the Debtors. Such rights, however, do not equate to a security interest in any assets related to Claim No Claim No. 881 therefore is not a secured claim. Moreover, to the extent that the claimant did have an interest in the goods reclaimed or returned under stoppage rights, it has, in fact, received the goods. Therefore, the claimant has no further in rem rights against the estates. Accordingly, the Debtors request an order reclassifying Claim No. 881, as set forth in Schedule 1. B. No Liability Claims 14. The Debtors object to Claim No. 1096, Claim No. 769, and Claim No. 960, listed in Schedule 2 to the attached proposed order, because the Debtors books and records do not 4

5 Case HJB Doc # 3074 Filed 02/08/16 Desc Main Document Page 5 of 7 show that the Debtors are liable to the claimants with regard to the matters asserted in the proofs of claim. Accordingly, the Debtors request an order disallowing and expunging these claims, as set forth in Schedule The Debtors also object to Claim No. 1098, listed in Schedule 2 to the attached proposed order. Following a review of the debtors books and records, the Debtors have determined that they are not liable for Claim No Specifically, pursuant to Bankruptcy Rule 3007(d)(7), the Debtors object to Claim No on the grounds that Claim No was asserted on account of equity interests held by the claimant, and is therefore not a claim as defined in section 101(5) of the Bankruptcy Code. The ownership of shares of stock (an equity interest) in GT Advanced Technologies, Inc. does not, in and of itself, constitute a claim against the Debtors estates as the term claim is defined in section 101(5) of the Bankruptcy Code. For this reason, the Debtors previously notified creditors, shareholders, and other parties in interest that they were not required to file proofs of claim based exclusively on ownership of shares of stock in GT Advanced Technologies, Inc. Accordingly, Claim No should be disallowed and expunged in its entirety. 16. In support of this Objection, the Debtors rely on the attached Declaration of Jay Herriman in Support of the Debtors Fourteenth Omnibus Objection to Claims (Reclassified and Modified Claims; No Liability Claims) (the Herriman Declaration ). RESERVATION OF RIGHTS 17. Nothing herein shall constitute an admission of liability by the Debtors with respect to any proof of claim. The Debtors reserve their rights to object to any proof of claim, including any claim listed on Schedules 1 or 2 to the proposed order, on any grounds whatsoever at a later date. 5

6 Case HJB Doc # 3074 Filed 02/08/16 Desc Main Document Page 6 of 7 NOTICE 18. Notice of the Objection has been provided by , facsimile, or overnight courier to (a) the Office of the United States Trustee for Region 1, 1000 Elm Street, Suite 605 Manchester, NH 03101, Attn Geraldine L. Karonis; (b) Kelley Drye & Warren LLP, 101 Park Avenue, New York, NY 10178, Attn James S. Carr, Esq., counsel to the Committee; (c) the Internal Revenue Service, 1000 Elm St., 9th Floor Manchester, NH 03101, Attn District and Regional Directors; (d) U.S. Securities and Exchange Commission, 100 F Street, NE, Washington, DC 20549; and (e) those parties who have formally filed requests for notice in these chapter 11 cases pursuant to Bankruptcy Rule In addition, in accordance with the Claims Procedures Order, notice has been provided to the claimants listed on Schedules 1 and 2 to the attached proposed order. [remainder of page intentionally left blank] 6

7 Case HJB Doc # 3074 Filed 02/08/16 Desc Main Document Page 7 of 7 WHEREFORE, the Debtors respectfully request entry of an order (i) granting the relief requested herein and (ii) granting such other and further relief as the Court deems just and proper. Dated February 8, 2016 /s/ G. Alexander Bongartz Luc A. Despins, Esq. James T. Grogan, Esq. (BNH07394) G. Alexander Bongartz, Esq. (BNH07449) PAUL HASTINGS LLP Park Avenue Tower 75 East 55th Street, First Floor New York, New York Telephone (212) Facsimile (212) and- Daniel W. Sklar, Esq. Holly J. Barcroft, Esq. NIXON PEABODY LLP 900 Elm Street Manchester, NH Telephone (603) Facsimile (603) Co-Counsel for the Debtors and Debtors in Possession 7

8 Case HJB Doc # Filed 02/08/16 Desc Exhibit A - Proposed Order Page 1 of 7 EXHIBIT A Proposed Order

9 Case HJB Doc # Filed 02/08/16 Desc Exhibit A - Proposed Order Page 2 of 7 UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW HAMPSHIRE x In re GT ADVANCED TECHNOLOGIES INC., et al., Debtors x Chapter 11 Case No HJB Jointly Administered RE Docket No. ORDER GRANTING DEBTORS FOURTEENTH OMNIBUS OBJECTION TO CLAIMS (RECLASSIFIED AND MODIFIED CLAIMS; NO LIABILITY CLAIMS) Upon consideration of the Debtors Fourteenth Omnibus Objection to Claims (Reclassified and Modified Claims; No Liability Claims) (the Objection ), 2 filed pursuant to section 502 of the Bankruptcy Code and Bankruptcy Rule 3007, seeking entry of an order (i) reclassifying and/or modifying the claims listed on Schedule 1 hereto; and (ii) disallowing and expunging the claims listed on Schedule 2 hereto, all as more fully set forth in the Objection; and upon consideration of the Herriman Declaration; and the court having jurisdiction to consider the Objection and the relief requested therein pursuant to 28 U.S.C. 157 and 1334; and due and adequate notice of the Objection having been given under the circumstances; and sufficient cause appearing therefor; it is hereby ORDERED that 1. The Objection is sustained as set forth herein. 1 2 The debtors in these chapter 11 cases, along with the last four digits of each debtor s tax identification number, as applicable, are GT Advanced Technologies Inc. (6749), GTAT Corporation (1760), GT Advanced Equipment Holding LLC (8329), GT Equipment Holdings, Inc. (0040), Lindbergh Acquisition Corp. (5073), GT Sapphire Systems Holding LLC (4417), GT Advanced Cz LLC (9815), GT Sapphire Systems Group LLC (5126), and GT Advanced Technologies Limited (1721). The Debtors corporate headquarters are located at 243 Daniel Webster Highway, Merrimack, NH Capitalized terms not otherwise defined herein shall have the meaning ascribed to such terms in the Objection.

10 Case HJB Doc # Filed 02/08/16 Desc Exhibit A - Proposed Order Page 3 of 7 2. The claims listed on Schedule 1 hereto are hereby reclassified and/or modified as specified in Schedule 1. their entirety. 3. The claims listed on Schedule 2 hereto are hereby disallowed and expunged in 4. The Debtors expressly reserve their rights to object to any of the claims listed on Schedule 1 hereto on any grounds whatsoever at a later date. 5. Nothing in the Objection or this Order constitutes a waiver of the Debtors rights to object to any claims not previously disallowed or to assert any claims, counterclaims, rights of offset or recoupment or any other claims against the claimants listed on Schedules 1 and 2 to this Order, all of which rights are expressly preserved. 6. KCC, the Debtors court-appointed notice and claims agent, is authorized and directed to reclassify and/or modify or disallow and expunge the claims as set forth in each Schedule pursuant to this Order on the official claims register in these chapter 11 cases. 7. This Court shall retain jurisdiction with respect to any matters, claims, rights, or disputes arising from or related to the Objection or the implementation of this Order. Dated, 2016 Manchester, NH HONORABLE HENRY J. BOROFF UNITED STATES BANKRUPTCY JUDGE

11 Case HJB Doc # Filed 02/08/16 Desc Exhibit A - Proposed Order Page 4 of 7 Schedule 1

12 Case HJB Doc # Filed 02/08/16 Desc Exhibit A - Proposed Order Page 5 of 7 GT Advanced Technologies Inc., et al. Fourteenth Omnibus Objection Schedule 1 Reclassified and Modified Claims NAME CLAIM # 1 SANMINA CORPORATION AND ITS SUBSIDIARY, SANMINA-SCI SYSTEMS (KUNSHAN) CO. LIMITED EDWARD T. ATTANASIO, ESQ. SANMINA CORPORATION 2700 NORTH FIRST STREET SAN JOSE, CA STEEL-PRO, INC. ANDREW C. HELMAN MARCUS, CLEGG & MISTRETTA, P.A. ONE CANAL PLAZA, SUITE 600 PORTLAND, ME FILED DATE DEBTOR /22/2015 GT Advanced Technologies Limited /26/2015 GT Advanced Technologies Limited ASSERTED CLASS 503(b)(9) Unsecured Secured Unsecured ASSERTED AMOUNT $597, $3,584,910.14* $1,819,459.00* Undetermined* MODIFIED CLASS 503(b)(9) Unsecured Secured Unsecured MODIFIED AMOUNT $597, $3,584, $0.00 $1,322, GROUNDS FOR OBJECTION Claimant also asserted an unliquidated component in addition to its claim of $4,194, According to their books and records the Debtors believe the fully liquidated amount of this claim is $4,194, Note - Claim previously modified on the Ninth Omnibus Objection (Reclassified and Modified 503(b)(9) Claims) Claim asserts secured status, but claimant is already in possession of goods that purport to secure this claim. In addition, the Debtors books and records reflect a liability owing to claimant of $1,322,424. Accordingly, the claim should be reclassified and reduced as set forth herein. * - Indicates claim contains unliquidated and/or undetermined amounts Page 1 of 1

13 Case HJB Doc # Filed 02/08/16 Desc Exhibit A - Proposed Order Page 6 of 7 Schedule 2

14 Case HJB Doc # Filed 02/08/16 Desc Exhibit A - Proposed Order Page 7 of 7 GT Advanced Technologies Inc., et al. Fourteenth Omnibus Objection Schedule 2 No Liability Claims 1 NIKOLIC, IVAN SONNENSHASSE 2 LUZERN, 6014 SWITZERLAND NAME CASE NUMBER (HJB) DEBTOR NAME GT Advanced Technologies Inc. FILED DATE CLAIM # TOTAL CLAIM DOLLARS REASON FOR PROPOSED DISALLOWANCE 01/20/ $178, Pursuant to Bankruptcy Rule 3007(d)(7), the Debtors object to this claim on the grounds that such claim is asserted on account of equity interests held by the claimant and is therefore not a "claim" as defined in section 101(5) of the Bankruptcy Code. Accordingly Debtors believe the claim should be disallowed and expunged in its entirety. Note Claim also contained on the Fifteenth Omnibus Objection (Late Filed Claims) 01/15/ $14, The Debtors books and records do not reflect a liability owing to this claimant with respect to the matters asserted in the proof of claim. 2 NILES EXPANDED METALS 310 NORTH PLEASANT AVENUE NILES, OH (HJB) GT Advanced Technologies Inc. 3 SILFAB S.P.A. N/K/A SILFAB S.R.L MARK MOEDRITZER SHOOK, HARDY & BACON L.L.P 2555 GRAND BLVD. KANSAS CITY, MO TAIWAN POLYSILICON CORP., 6F, NO. 85, SEC 4 BLADE ROAD TAIPEI, TAIWAN, PROVINCE OF CHINA (HJB) (HJB) Accordingly, the claim should be disallowed and expunged in its entirety. GT Advanced Cz LLC 01/23/ $2,000, The Debtors books and records do not reflect a liability owing to this claimant with respect to the matters asserted in the proof of claim. GT Advanced Technologies Inc. Accordingly, the claim should be disallowed and expunged in its entirety. 01/26/ $1,200, The Debtors books and records do not reflect a liability owing to this claimant with respect to the matters asserted in the proof of claim. Accordingly, the claim should be disallowed and expunged in its entirety. Page 1 of 1

15 Case HJB Doc # Filed 02/08/16 Desc Exhibit B - Herriman Declaration Page 1 of 4 EXHIBIT B Herriman Declaration

16 Case HJB Doc # Filed 02/08/16 Desc Exhibit B - Herriman Declaration Page 2 of 4 UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW HAMPSHIRE x In re GT ADVANCED TECHNOLOGIES INC., et al., Debtors x Chapter 11 Case No HJB Jointly Administered DECLARATION OF JAY HERRIMAN IN SUPPORT OF THE DEBTORS FOURTEENTH OMNIBUS OBJECTION TO CLAIMS (RECLASSIFIED AND MODIFIED CLAIMS; NO LIABILITY CLAIMS) I, Jay Herriman, hereby declare as follows BACKGROUND 1. I am a Managing Director with Alvarez & Marsal North America, LLC ( A&M ). By order, dated November 5, 2014 [Docket No. 445], the Debtors were, among other things, authorized to retain A&M as restructuring advisors. 2. I make this declaration in support of the Debtors Fourteenth Omnibus Objection to Claims (Reclassified and Modified Claims; No Liability Claims) (the Objection ) In my capacity as Managing Director of A&M, I am one of the persons responsible for overseeing the claims reconciliation and objection process in the Debtors chapter 11 cases. The Debtors ongoing claims reconciliation process involves the collective effort of a 1 2 The debtors in these chapter 11 cases, along with the last four digits of each debtor s tax identification number, as applicable, are GT Advanced Technologies Inc. (6749), GTAT Corporation (1760), GT Advanced Equipment Holding LLC (8329), GT Equipment Holdings, Inc. (0040), Lindbergh Acquisition Corp. (5073), GT Sapphire Systems Holding LLC (4417), GT Advanced Cz LLC (9815), GT Sapphire Systems Group LLC (5126), and GT Advanced Technologies Limited (1721). The Debtors corporate headquarters are located at 243 Daniel Webster Highway, Merrimack, NH Capitalized terms not otherwise defined herein shall have the meaning ascribed to such terms in the Objection.

17 Case HJB Doc # Filed 02/08/16 Desc Exhibit B - Herriman Declaration Page 3 of 4 team of employees of A&M and the Debtors, as well as the Debtors counsel, Paul Hastings LLP and Nixon Peabody LLP, and the Debtors notice and claims agent, Kurtzman Carson Consultants LLC. All facts set forth in this Declaration are based on my personal knowledge, my review of proofs of claim and other relevant documents, or information provided by the Debtors employees and advisors, and, as to matters involving United States bankruptcy law or rules or other applicable laws, my reliance on the advice of counsel or other advisors to the Debtors. If I were called upon to testify, I could and would testify to each of the facts set forth herein. CLAIMS OBJECTION 4. I, or one or more of the Debtors employees or advisors operating under my supervision and/or at my direction, have reviewed the books and records, the schedules of assets and liabilities and statements of financial affairs filed by each Debtor, each of the proofs of claim identified in the Objection, the claims register, and the facts and circumstances set forth in the Objection regarding such proofs of claim. Based on this review, and upon consultation with the Debtors counsel, I submit that the facts and circumstances set forth in the Objection are true and accurate to the best of my knowledge, information, and belief, and the proofs of claim listed on Schedules 1 and 2 to the attached to the proposed order filed with the Objection should be reclassified and/or modified or disallowed and expunged as set forth in the Objection. [remainder of page intentionally left blank] 2

18 Case HJB Doc # Filed 02/08/16 Desc Exhibit B - Herriman Declaration Page 4 of 4 Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Dated February 8, 2016 Respectfully submitted, /s/ Jay Herriman Jay Herriman Managing Director Alvarez & Marsal North America, LLC

19 Case HJB Doc # Filed 02/08/16 Desc Notice of Hearing Page 1 of 2 HEARING DATE AND TIME April 14, 2016 at 1000 a.m. (Eastern Time) OBJECTION DEADLINE February 29, 2016 at 400 p.m. (Eastern Time) UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW HAMPSHIRE x In re Chapter 11 GT ADVANCED TECHNOLOGIES INC., et al., Case No HJB Debtors. 1 Jointly Administered x NOTICE OF HEARING ON DEBTORS FOURTEENTH OMNIBUS OBJECTION TO CLAIMS (RECLASSIFIED AND MODIFIED CLAIMS; NO LIABILITY CLAIMS) PLEASE TAKE NOTICE that a hearing on the Debtors Fourteenth Omnibus Objection to Claims (Reclassified and Modified Claims; No Liability Claims) (the Objection ) 2 will be held on April 14, 2016 at 1000 a.m. (Eastern Time) at the United States Bankruptcy Court for the District of New Hampshire, 1000 Elm Street, 11th Floor, Manchester, New Hampshire PLEASE TAKE FURTHER NOTICE that objections or responses, if any, to the Objection must be in writing, shall conform to the Bankruptcy Rules and the Local Bankruptcy Rules, and shall be (a) filed with the Court on the docket of In re GT Advanced Technologies, Inc., Case No HJB, and (b) served upon (i) the Clerk of the Bankruptcy Court, 1000 Elm Street, Suite 1001, Manchester, NH ; (ii) Paul Hastings LLP, 75 East 55th Street, New York, NY 10022, Attn Luc A. Despins, Esq., and 600 Travis Street, 58th Floor, Houston, 1 2 The Debtors, along with the last four digits of each debtor s tax identification number, as applicable, are GT Advanced Technologies Inc. (6749), GTAT Corporation (1760), GT Advanced Equipment Holding LLC (8329), GT Equipment Holdings, Inc. (0040), Lindbergh Acquisition Corp. (5073), GT Sapphire Systems Holding LLC (4417), GT Advanced Cz LLC (9815), GT Sapphire Systems Group LLC (5126), and GT Advanced Technologies Limited (1721). The Debtors corporate headquarters are located at 243 Daniel Webster Highway, Merrimack, NH Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the Objection.

20 Case HJB Doc # Filed 02/08/16 Desc Notice of Hearing Page 2 of 2 TX 77002, Attn James T. Grogan, Esq., and Nixon Peabody LLP, 900 Elm Street, Manchester, NH 03101, Attn Daniel W. Sklar, Esq. and Holly J. Barcroft, Esq.; and (iii) Kelley Drye & Warren LLP, 101 Park Avenue, New York, NY 10178, Attn James S. Carr, Esq., so as to be received no later than February 29, 2016 at 400 p.m. (Eastern Time) (the Objection Deadline ). PLEASE TAKE FURTHER NOTICE that if no objections are timely filed and served with respect to the Objection, GTAT may, on or after the Objection Deadline, submit to the Bankruptcy Court an order substantially in the form of the proposed order annexed to the Objection, which order may be entered with no further notice or opportunity to be heard offered to any party. Dated February 8, 2016 /s/ G. Alexander Bongartz. Luc A. Despins, Esq. James T. Grogan, Esq. (BNH07394) G. Alexander Bongartz, Esq. (BNH07449) PAUL HASTINGS LLP Park Avenue Tower 75 East 55th Street, First Floor New York, New York Telephone (212) Facsimile (212) and- Daniel W. Sklar, Esq. Holly J. Barcroft, Esq. NIXON PEABODY LLP 900 Elm Street Manchester, NH Telephone (603) Facsimile (603) Co-Counsel for the Debtors and Debtors in Possession 2