PLEASE TAKE NOTICE that on October 12, 2018, W Wind Down Co LLC ( Wind

Transcription

1 Hearing Date and Time: November 16, 2018 at 11:00 a.m. (ET) Martin J. Bienenstock Timothy Q. Karcher Vincent Indelicato PROSKAUER ROSE LLP Eleven Times Square New York, NY Tel: (212) Fax: (212) Counsel to the Statutory Unsecured Claimholders Committee of Westinghouse Electric, et al Alan W. Kornberg Kyle Kimpler Lauren Shumejda PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, NY Tel: (212) Fax: (212) Counsel to W Wind Down Co LLC UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re, et al., Debtors. 1 Chapter 11 Case No (MEW) (Jointly Administered) RE: ECF Nos and 4065 NOTICE OF FILING OF REVISED ORDER AND REVISED SCHEDULES IN CONNECTION WITH FIRST MOTION OF WIND DOWN CO AND STATUTORY UNSECURED CLAIMHOLDERS COMMITTEE (I) OBJECTING TO AND (II) SEEKING ESTIMATION OF UNLIQUIDATED CLAIMS FOR ALL PURPOSES UNDER CHAPTER 11 PLAN PLEASE TAKE NOTICE that on October 12, 2018, W Wind Down Co LLC ( Wind Down Co ) and the Statutory Unsecured Claimholders Committee (the UCC, and together 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, if any, are: (0933), CE Nuclear Power International, Inc. (8833), Fauske and Associates LLC (8538), Field Services, LLC (2550), Nuclear Technology Solutions LLC (1921), PaR Nuclear Holding Co., Inc. (7944), PaR Nuclear, Inc. (6586), PCI Energy Services LLC (9100), Shaw Global Services, LLC (0436), Shaw Nuclear Services, Inc. (6250), Stone & Webster Asia Inc. (1348), Stone & Webster Construction Inc. (1673), Stone & Webster International Inc. (1586), Stone & Webster Services LLC (5448), Toshiba Nuclear Energy Holdings (UK) Limited (2348), TSB Nuclear Energy Services Inc. (2348), WEC Carolina Energy Solutions, Inc. (8735), WEC Carolina Energy Solutions, LLC (2002), WEC Engineering Services Inc. (6759), WEC Equipment & Machining Solutions, LLC (3135), WEC Specialty LLC (N/A), WEC Welding and Machining, LLC (8771), WECTEC Contractors Inc. (4168), WECTEC Global Project Services Inc. (8572), WECTEC LLC (6222), WECTEC Staffing Services LLC (4135), Westinghouse Energy Systems LLC (0328), Westinghouse Industry Products International (3909), Westinghouse International Technology LLC (N/A), and Westinghouse Technology Licensing (5961). By order dated September 25, 2018, [ECF No. 3956] the administration of the Debtors cases was consolidated at the case of Company LLC, and the affiliated cases of certain Debtors were closed.

2 with Wind Down Co, the Movants ) of, et al. (the Debtors ) filed the Notice of Hearing to Consider First Motion of Wind Down Co And Statutory Unsecured Claimholders Committee (I) Objecting to and (II) Seeking Estimation of Unliquidated Claims for All Purposes Under Chapter 11 Plan, (the Motion ) [ECF No. 4049]. Attached as Exhibit A to the Motion was a proposed order (the Proposed Order ). Pursuant to the Proposed Order, Movants seek to (i) object to and (ii) estimate Claims listed on Schedule 1 and Schedule 2 attached thereto (the Original Schedules ). PLEASE TAKE FURTHER NOTICE that the Movants received informal requests for clarifications to the Proposed Order ( Requests for Clarifications ) from claimants (a) American Tank and Vessel, Inc., and IHI Corp. regarding their requests for revised language in the Proposed Order, (b) General Atomics regarding its assertion that the unsecured liquidated amount and Maximum Limitation of Claim 3668 should be increased; (c) HSG Constructors, LLC regarding an opportunity to resolve all of its claims on Schedule 1; (d) the Mississippi Department of Revenue regarding its assertion that all of its claims on Schedule 2 should be withdrawn. PLEASE TAKE FURTHER NOTICE that, in response to the Requests for Clarifications, the Movants have revised the Proposed Order to reflect (a) the proposed language as requested by American Tank and Vessel, Inc., and IHI Corp.; (b) an increase in the unsecured liquidated amount and Maximum Limitation of General Atomics Claim 3668 as reflected in Schedule 1; (c) a consensual resolution of HSG Constructors, LLC s claims resulting in removal of its claims from Schedule 1; and (d) a consensual resolution of the Mississippi Department of Revenue s claims resulting in removal of its claims from Schedule 2. PLEASE TAKE FURTHER NOTICE that, in addition to the Requests for 2

3 Clarification, the Movants received a formal objection to the Motion from Department of Taxation, State of Hawaii, titled Declaration of Elayne Liu Regarding Department of Taxation, State of Hawaii s Response to First Motion of Wind Down Co and Statutory Unsecured Claimholders Committee (I) Objecting to and (II) Seeking Estimation of Unliquidated Claims for All Purposes Under Chapter 11 Plan; Exhibits A C [ECF No. 4065] (the Objection ), objecting to the calculation of its estimated unsecured liquidated amount and Maximum Limitation of its claim. PLEASE TAKE FURTHER NOTICE that, in response to the Objection, the Movants removed the Department of Taxation, State of Hawaii s claims from Schedule 2 but intend to estimate their claim at the hearing to be held on November 16, 2018, or such other time as the parties may agree or the Court may direct. Movants will set forth any estimation or other resolution of the Department of Taxation, State of Hawaii s claims in a separate order. PLEASE TAKE FURTHER NOTICE that, in light of the action taken on the Requests for Clarification and Objection, Movants have (i) revised the Proposed Order (the Revised Order ) and (ii) amended (as appropriate) Schedule 1 and Schedule 2 (the Revised Schedules ), as reflected in the form attached hereto as Exhibit A. PLEASE TAKE FURTHER NOTICE that a redline comparing the Proposed Order and Original Schedules to the Revised Order and Revised Schedules is attached hereto as Exhibit B, demonstrating cumulative changes. 3

4 PLEASE TAKE FURTHER NOTICE that, in light of the (i) incorporation of clarifying language in the Revised Order, and (ii) changes reflected on the Revised Schedules, no objections remain with respect to the Unliquidated Claims on the Revised Schedules and the Movants request that the Revised Order with the Revised Schedules be entered. Dated: November 13, 2018 New York, New York Respectfully submitted, /s/ Timothy Q. Karcher Martin J. Bienenstock Timothy Q. Karcher Vincent Indelicato PROSKAUER ROSE LLP Eleven Times Square New York, NY Tel: (212) Fax: (212) Counsel to the Statutory Unsecured Claimholders Committee of, et al. And /s/ Kyle Kimpler Alan W. Kornberg Kyle Kimpler Lauren Shumejda PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, NY Tel: (212) Fax: (212) Counsel to W Wind Down Co LLC 4

5 Exhibit A REVISED ORDER and REVISED SCHEDULES

6 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re, et al., Debtors. 1 Chapter 11 Case No (MEW) (Jointly Administered) ORDER GRANTING FIRST MOTION OF WIND DOWN CO AND STATUTORY UNSECURED CLAIMHOLDERS COMMITTEE (I) OBJECTING TO AND (II) SEEKING ESTIMATION OF UNLIQUIDATED CLAIMS FOR ALL PURPOSES UNDER CHAPTER 11 PLAN Upon the First Motion of Wind Down Co And Statutory Unsecured Claimholders Committee (I) Objecting to and (II) Seeking Estimation of Unliquidated Claims for All Purposes Under Chapter 11 Plan (the Motion ); 2 pursuant to Bankruptcy Code sections 105(a), 502(c), and 1142(b), Bankruptcy Rules 3007 and 3021, and the confirmed Plan, seeking entry of an order (i) fixing the Maximum Limitation of the partially liquidated Claims set forth on Schedule 1, annexed hereto, in the liquidated amount of such Claims, (ii) disallowing the unliquidated portion of the partially liquidated Claims set forth on Schedule 1, and (iii) disallowing certain unliquidated Claims in their entirety as set forth on Schedule 2, annexed hereto; and the Court having found that the Court has subject matter jurisdiction over this matter pursuant to 28 U.S.C. 1334, section 13 of the Plan, and the Confirmation Order; and the Court having found that the Motion is a core proceeding under 28 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, if any, are: (0933), CE Nuclear Power International, Inc. (8833), Fauske and Associates LLC (8538), Field Services, LLC (2550), Nuclear Technology Solutions LLC (1921), PaR Nuclear Holding Co., Inc. (7944), PaR Nuclear, Inc. (6586), PCI Energy Services LLC (9100), Shaw Global Services, LLC (0436), Shaw Nuclear Services, Inc. (6250), Stone & Webster Asia Inc. (1348), Stone & Webster Construction Inc. (1673), Stone & Webster International Inc. (1586), Stone & Webster Services LLC (5448), Toshiba Nuclear Energy Holdings (UK) Limited (2348), TSB Nuclear Energy Services Inc. (2348), WEC Carolina Energy Solutions, Inc. (8735), WEC Carolina Energy Solutions, LLC (2002), WEC Engineering Services Inc. (6759), WEC Equipment & Machining Solutions, LLC (3135), WEC Specialty LLC (N/A), WEC Welding and Machining, LLC (8771), WECTEC Contractors Inc. (4168), WECTEC Global Project Services Inc. (8572), WECTEC LLC (6222), WECTEC Staffing Services LLC (4135), Westinghouse Energy Systems LLC (0328), Westinghouse Industry Products International (3909), Westinghouse International Technology LLC (N/A), and Westinghouse Technology Licensing (5961). The Debtors principal offices are located at 1000 Westinghouse Drive, Cranberry Township, Pennsylvania By order dated September 25, 2018, [ECF No. 3956] the administration of the Debtors cases was consolidated at the case of, and the affiliated cases of certain Debtors were closed. 2 Capitalized terms used but not otherwise defined herein shall have the meanings set forth in the Motion.

7 U.S.C. 157(b)(2); and it appearing that venue of this proceeding and the Motion in this district is proper pursuant to 28 U.S.C and 1409; and the Court having found that Wind Down Co and the UCC provided due and proper notice of the Motion in accordance with Bankruptcy Rule 3007 and the Order Pursuant to 11 U.S.C. 105(a) and Fed. R. Bankr. P. 1015(c) and 9007 Implementing Certain Notice and Case Management Procedures; and the Court, upon review of the Motion and the Notice, having determined that the legal and factual bases set forth in the Motion establish just cause for the relief requested therein and granted herein; and after due deliberation and sufficient cause appearing therefor, it is 1. ORDERED that the Motion is approved and granted to the extent set forth herein and with respect to the Claims listed on Schedule 1 and Schedule 2 hereto; and it is further 2. ORDERED that the unliquidated portions of the Claims listed on Schedule 1 shall be disallowed to the extent that such unliquidated portions (together with any liquidated portions of such Claims) exceed the Maximum Limitation on Schedule 1, and such Claims shall be estimated in the amount identified in the column entitled Maximum Limitation on Schedule 1; and it is further 3. ORDERED that each of the Claims listed on Schedule 2 shall be disallowed in their entirety and such Claims shall be estimated in the amount identified in the column entitled Maximum Limitation on Schedule 2; and it is further 4. ORDERED that the Maximum Limitation for each Claim listed on Schedule 1 and Schedule 2 shall govern for all purposes under the Plan, including distributions, and shall be the maximum limitation of the amount of such Claims, such that, in no event will the Allowed Amount of any such Claim be greater than the Maximum Limitation established by this Order; and it is further 5. ORDERED that no Claims are being Allowed by this Motion and each Claim identified on Schedule 1 and Schedule 2 shall remain Disputed for all purposes, pending further order of the Court or the agreement of Wind Down Co and the UCC; and it is further

8 6. ORDERED that the Claims may be subject to further or additional objections by any party, including Wind Down Co, prior to the deadline for filing objections to General Unsecured Claims (as such deadline may be extended by this Court); and it is further 7. ORDERED that Wind Down Co, the UCC, and KCC are authorized to take all actions necessary to effectuate the relief granted in this Order; and it is further 8. ORDERED that the Court shall retain jurisdiction to hear and determine all matters arising from or related to the implementation, interpretation, and/or enforcement of this Order. Dated:, 2018 New York, New York The Honorable Michael E. Wiles United States Bankruptcy Judge

9 Schedule 1

10

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13 Schedule 2

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17 Exhibit B Redlines

18 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re, et al., Debtors. 1 Chapter 11 Case No (MEW) (Jointly Administered) ORDER GRANTING FIRST MOTION OF WIND DOWN CO AND STATUTORY UNSECURED CLAIMHOLDERS COMMITTEE (I) OBJECTING TO AND (II) SEEKING ESTIMATION OF UNLIQUIDATED CLAIMS FOR ALL PURPOSES UNDER CHAPTER 11 PLAN Upon the First Motion of Wind Down Co And Statutory Unsecured Claimholders Committee (I) Objecting to and (II) Seeking Estimation of Unliquidated Claims for All Purposes Under Chapter 11 Plan (the Motion ); 2 pursuant to Bankruptcy Code sections 105(a), 502(c), and 1142(b), Bankruptcy Rules 3007 and 3021, and the confirmed Plan, seeking entry of an order (i) fixing the Maximum Limitation of the partially liquidated Claims set forth on Schedule 1, annexed hereto, in the liquidated amount of such Claims, (ii) disallowing the unliquidated portion of the partially liquidated Claims set forth on Schedule 1, and (iii) disallowing certain unliquidated Claims in their entirety as set forth on Schedule 2, annexed hereto; and the Court having found that the Court has subject matter jurisdiction over this matter pursuant to 28 U.S.C. 1334, section 13 of the Plan, and the Confirmation Order; and the Court having found that the Motion is a core proceeding under 28 U.S.C. 157(b)(2); and it appearing that venue of this proceeding and the Motion in this district is 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, if any, are: (0933), CE Nuclear Power International, Inc. (8833), Fauske and Associates LLC (8538), Field Services, LLC (2550), Nuclear Technology Solutions LLC (1921), PaR Nuclear Holding Co., Inc. (7944), PaR Nuclear, Inc. (6586), PCI Energy Services LLC (9100), Shaw Global Services, LLC (0436), Shaw Nuclear Services, Inc. (6250), Stone & Webster Asia Inc. (1348), Stone & Webster Construction Inc. (1673), Stone & Webster International Inc. (1586), Stone & Webster Services LLC (5448), Toshiba Nuclear Energy Holdings (UK) Limited (2348), TSB Nuclear Energy Services Inc. (2348), WEC Carolina Energy Solutions, Inc. (8735), WEC Carolina Energy Solutions, LLC (2002), WEC Engineering Services Inc. (6759), WEC Equipment & Machining Solutions, LLC (3135), WEC Specialty LLC (N/A), WEC Welding and Machining, LLC (8771), WECTEC Contractors Inc. (4168), WECTEC Global Project Services Inc. (8572), WECTEC LLC (6222), WECTEC Staffing Services LLC (4135), Westinghouse Energy Systems LLC (0328), Westinghouse Industry Products International (3909), Westinghouse International Technology LLC (N/A), and Westinghouse Technology Licensing (5961). The Debtors principal offices are located at 1000 Westinghouse Drive, Cranberry Township, Pennsylvania By order dated September 25, 2018, [ECF No. 3956] the administration of the Debtors cases was consolidated at the case of, and the affiliated cases of certain Debtors were closed. 2 Capitalized terms used but not otherwise defined herein shall have the meanings set forth in the Motion. 2534/ CURRENT/ v2 10/04/2018 8:06 PM

19 proper pursuant to 28 U.S.C and 1409; and the Court having found that Wind Down Co and the UCC provided due and proper notice of the Motion in accordance with Bankruptcy Rule 3007 and the Order Pursuant to 11 U.S.C. 105(a) and Fed. R. Bankr. P. 1015(c) and 9007 Implementing Certain Notice and Case Management Procedures; and the Court, upon review of the Motion and the Notice, having determined that the legal and factual bases set forth in the Motion establish just cause for the relief requested therein and granted herein; and after due deliberation and sufficient cause appearing therefor, it is 1. ORDERED that the Motion is approved and granted to the extent set forth herein and with respect to the Claims listed on Schedule 1 and Schedule 2 hereto; and it is further 2. ORDERED that the unliquidated portions of the Claims listed on Schedule 1 shall be disallowed to the extent that such unliquidated portions (together with any liquidated portions of such Claims) exceed the Maximum Limitation on Schedule 1, and such Claims shall be estimated in the amount identified in the column entitled Maximum Limitation on Schedule 1; and it is further 3. ORDERED that each of the Claims listed on Schedule 2 shall be disallowed in their entirety and such Claims shall be estimated in the amount identified in the column entitled Maximum Limitation on Schedule 2; and it is further 4. ORDERED that the Maximum Limitation for each Claim listed on Schedule 1 and Schedule 2 shall govern for all purposes under the Plan, including distributions, and shall be the maximum limitation of the amount of such Claims, such that, in no event will the Allowed Amount of any such Claim be greater than the Maximum Limitation established by this Order; and it is further v2 2534/ CURRENT/ v2 10/04/2018 8:06 PM

20 5. ORDERED that no Claims are being Allowed by this Motion and each Claim identified on Schedule 1 and Schedule 2 shall remain Disputed for all purposes, pending further order of the Court or the agreement of Wind Down Co and the UCC; and it is further 6. ORDERED that the Claims may be subject to further or additional objections by any party, including Wind Down Co, prior to the deadline for filing objections to General Unsecured Claims (as such deadline may be extended by this Court; and it is further 7. ORDERED that Wind Down Co, the UCC, and KCC are authorized to take all actions necessary to effectuate the relief granted in this Order; and it is further 8. ORDERED that the Court shall retain jurisdiction to hear and determine all matters arising from or related to the implementation, interpretation, and/or enforcement of this Order. Dated:, 2018 New York, New York The Honorable Michael E. Wiles United States Bankruptcy Judge v2 2534/ CURRENT/ v2 10/04/2018 8:06 PM

21 Document comparison by Workshare Compare on Tuesday, November 13, :21:01 PM Input: Document 1 ID Description Document 2 ID Description Rendering set Legend: Insertion Deletion Moved from Moved to Style change Format change Moved deletion Inserted cell Deleted cell Moved cell Split/Merged cell Padding cell Statistics: file://\\na.proskauer.com\firm\home\ny3\2534\desktop\w EC Notice & Estimation\Motion 1\Original Proposed Order.DOCX Original Proposed Order file://\\na.proskauer.com\firm\home\ny3\2534\desktop\w EC Notice & Estimation\Motion 1\Revised Proposed Order.doc Revised Proposed Order Standard Count Insertions 3 Deletions 3 Moved from 0 Moved to 0 Style change 0 Format changed 0

22 Total changes 6

23 Schedule / CURRENT/ v1 11/08/2018 6:46 PM9359/ CURRENT/ v2 11/09/2018 5:40 PM

24 First Motion Objecting to and Seeking Estimation Of Unliquidated Claims Schedule 1 Claims Asserted in Partially Unliquidated Amounts Claimant Name Claimant Address Debtor Name Filed Date Claim to be Estimated Unsecured Liquidated Amount Unsecured Unliquidated Amount* Estimated Unsecured Unliquidated Amount Maximum Limitation Ground(s) for Objection to Unliquidated Portion of Claim 1. Acuren Inspection, Inc. Acuren Inspection, Inc. McGuireWoods LLP, c/o Joseph S. Sheerin, Esq. PCI Energy Services 9/1/ $736, Undetermined $0.00 $736, Claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is Gateway Plaza 800 East Canal Street Richmond, VA, USA 2. Acuren Inspection, Inc. Acuren Inspection, Inc. McGuireWoods LLP, c/o Joseph S. Sheerin, Esq. Gateway Plaza 800 East Canal Street Richmond, Virginia, USA PCI Energy Services 9/1/ $367, Undetermined $0.00 $367, Claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is 3. American Tank and Vessel, Inc. American Tank and Vessel, Inc. Joshua W. Wolfshohl, Porter Hedges LLP 1000 Main Street, 36th Floor Houston, TX /31/ $2,258, Undetermined $0.00 $2,258, Claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is unliquidated it should be estimated at zero dollars. American Tank and Vessel, Inc. American Tank and Vessel, Inc. 4. Joshua W. Wolfshohl, Porter Hedges LLP 1000 Main Street, 36th Floor Houston, TX Automated Precision, Inc. Automated Precision, Inc. 5. Allen Frydenberg, CFO John Hopkins Drive Rockville, MD, USA 6. Bigge Crane and Rigging Co. Bigge Crane and Rigging Co. Attn: Thom Bostrom Bigge St. San Leandro, CA 94577, United States WECTEC Contractors Inc. WECTEC Global Project Services Inc. Stone & Webster Construction Inc. 8/31/ $3,642, Undetermined $0.00 $3,642, Claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is unliquidated it should be estimated at zero dollars. 8/28/ $731, Undetermined $0.00 $731, Claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is 3/20/ $737, Undetermined $0.00 $737, Claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is 7. Cannon Sline Industrial, Inc. Paul F. O Donnell, III c/o Hinckley, Allen & Snyder LLP 28 State Street Boston, MA WECTEC Contractors Inc. 8/8/ $4,599, Undetermined $0.00 $4,599, Claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is 8. CB&I Laurens, Inc. CB and I Laurens, Inc. Logan Hollobaugh 2103 Research Forest Drive The Woodlands, TX, WECTEC Global Project Services Inc. 3/8/ $8,975, Undetermined $0.00 $8,975, Claim is apparently protective. Furthermore, claim lacks sufficient documentation to verify the basis of the unliquidated amount. To the extent the claim is 9. CBI Services LLC CBI Services LLC Logan Hollobaugh 2103 Research Forest Drive The Woodlands, TX /9/ $25,515, Undetermined $0.00 $25,515, Claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is 9359/ CURRENT/ v1 11/08/2018 6:46 PM9359/ CURRENT/ v2 11/09/2018 5:40 PM

25 Claimant Name Claimant Address Debtor Name Filed Date 10. COMANCO Environmental Corporation COMANCO Environmental Corporation 4301 Sterling Commerce Dr. Plant City, FL WECTEC Contractors Inc. Estimated Claim to be Unsecured Unsecured Maximum Estimated Unsecured Unliquidated Unliquidated Limitation Liquidated Amount Amount* Amount Ground(s) for Objection to Unliquidated Portion of Claim 6/9/ $119, Undetermined $0.00 $119, Claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is 11. Cross, Michael Michael Cross 11 Sutton Dr. Vernon, CT Environmental Resources Management, Inc. Environmental Resources Management, Inc. c/o Gina Shearer, Strasburger & Price LLP 2600 Dallas Parkway, Ste. 600 Frisco, TX General Atomics General Atomics General Atomics - Law Department 3550 General Atomics Court San Diego, CA, General Atomics General Atomics General Atomics - Law Department 3550 General Atomics Court San Diego, CA Global Chem-Feed Solutions William J. Herbert 2015 Stout Drive Warminster, P.A USA ; CE Nuclear Power International, Inc.; Toshiba Nuclear Energy Holdings (UK) Ltd Company, LLC 8/31/ $22, Undetermined $0.00 $22, Claim is apparently protective. Furthermore, Debtors informed movants that they reviewed books and records and the claim seeks an unliquidated amount for which the Debtors are not liable. Furthermore, claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is unliquidated it should be estimated at zero dollars. 5/11/ $1, Undetermined $0.00 $1, Claim lacks sufficient documentation to verify the basis of any unliquidated amount. To the extent the claim is 9/1/ $344, Undetermined $0.00 $344, Claim lacks sufficient documentation to verify the basis of any unliquidated amount. To the extent the claim is 8/31/ $534, Undetermined $0.00 $534, ,034, Debtors informed movants that they reviewed books and records and the claim seeks an unliquidated amount for which the Debtors are not liable. Furthermore, claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is Maximum Limitation increased by $2.5M per agreement with counsel. 2/8/ $25, Undetermined $0.00 $25, Claim lacks sufficient documentation to verify the basis of the unliquidated amount. To the extent the claim is 16. Gutor Electronic LLP Gutor Electronic LLP Jennifer V. Doran, Esq., Hinckley Allen Snyder 28 State Street Boston, MA, USA 17. HSG Constructors, LLC HSG Constructors, LLC 5730 FM 646 East Dickinson, TX Stone & Webster Construction Inc. 10/20/ $4,519, Undetermined $0.00 $4,519, Claim lacks sufficient documentation to verify the basis of the unliquidated amount. To the extent the claim is 8/31/ $34, Undetermined $0.00 $34, Claim lacks sufficient documentation to verify the basis of the unliquidated amount. To the extent the claim is 9359/ CURRENT/ v1 11/08/2018 6:46 PM9359/ CURRENT/ v2 11/09/2018 5:40 PM 2

26 Claimant Name Claimant Address Debtor Name Filed Date 18. HSG Constructors, LLC HSG Constructors, LLC 5730 FM 646 East Dickinson, TX WECTEC Global Project Services Inc. Estimated Claim to be Unsecured Unsecured Maximum Estimated Unsecured Unliquidated Unliquidated Limitation Liquidated Amount Amount* Amount Ground(s) for Objection to Unliquidated Portion of Claim 8/31/ $4,069, Undetermined $0.00 $4,069, Claim lacks sufficient documentation to verify the basis of the unliquidated amount. To the extent the claim is 17. IHI Corp IHI Corp., 1 Shin-Nakahara-Cho, Isogo-Ku, Yokahama, Japan /31/ $307, Undetermined $0.00 $307, Claim lacks sufficient documentation to verify the basis of the unliquidated amount. To the extent the claim is 18. IHI Corp IHI Corp., 1 Shin-Nakahara-Cho, Isogo-Ku, Yokahama, Japan WECTEC Global Project Services Inc. 8/31/ $34,524, Undetermined $0.00 $34,524, Claim lacks sufficient documentation to verify the basis of the unliquidated amount. To the extent the claim is 19. IX WR Glen Lake Drive, L.P. 1. Kirkland & Ellis LLP, Attn: Christopher Marcus, P.C. 601 Lexington Avenue New York, NY USA 8/23/ $4, Undetermined $0.00 $4, Claim appears to be protective claim. Furthermore, claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is 20. IX WR Glen Lake Drive, L.P IX WR Glen Lake Drive, L.P. 3. Kirkland & Ellis LLP, Attn: Christopher Marcus, P.C. 601 Lexington Avenue New York, NY USA Kirkland & Ellis LLP, Attn: Christopher Marcus, P.C. 601 Lexington Avenue New York, NY USA WECTEC LLC 8/23/ $10, Undetermined $0.00 $10, Claim lacks sufficient documentation to verify the basis of the unliquidated amount. To the extent the claim is WECTEC LLC 8/23/ $4, Undetermined $0.00 $4, Claim lacks sufficient documentation to verify the basis of the unliquidated amount. To the extent the claim is 22. IX WR Glen Lake Drive, L.P. 4. Kirkland & Ellis LLP, Attn: Christopher Marcus, P.C. 601 Lexington Avenue New York, NY USA Company, LLC 8/23/ $10, Undetermined $0.00 $10, Claim appears to be protective claim. Furthermore, claim lacks sufficient documentation to verify the basis for any unliquidated amount. To the extent the claim is * Undetermined means the proof of claim either did not state the dollar amount of the claim or stated that such amount was unknown. 9359/ CURRENT/ v1 11/08/2018 6:46 PM9359/ CURRENT/ v2 11/09/2018 5:40 PM 3

27 Document comparison by Workshare Compare on Friday, November 9, :12:14 PM Input: Document 1 ID Description Document 2 ID Description Rendering set Legend: Insertion Deletion Moved from Moved to Style change Format change Moved deletion Inserted cell Deleted cell Moved cell Split/Merged cell Padding cell Statistics: interwovensite://dms/current/ /1 # v1<CURRENT> - Estimation Mtn 1_Sch 1_Part Unliq Claims interwovensite://dms/current/ /2 # v2<CURRENT> - Estimation Mtn 1_Sch 1_Part Unliq Claims Standard Count Insertions 11 Deletions 36 Moved from 0

28 Schedule / CURRENT/ v1 11/08/2018 6:58 PM9359/ CURRENT/ v2 11/09/2018 2:09 PM

29 First Motion Objecting to and Seeking Estimation Of Unliquidated Claims Schedule 2 Claims Asserted in Fully Unliquidated Amounts Claimant Name Claimant Address Debtor Name Filed Date Claim to be Estimated Unsecured Unliquidated Amount Sought* Estimated Unsecured Unliquidated Amount Maximum Limitation Ground(s) for Objection to Unliquidated Claim 1. AB Produktions Service APS AB Produktions Service APS, Spjutvagen 4, Jarfalla 12, Sweden 8/31/ Undetermined $0.00 $0.00 Claim lacks sufficient documentation to verify the basis of the unliquidated amount. 2. ATEQ ATEQ Rue Des Dames 15, Les Clayes Sous Bois, France None Indicated 7/25/ Undetermined $0.00 $0.00 Claim lacks sufficient documentation to verify the basis of the unliquidated amount. 3. Bullock, Garry Garry Bullock 407 Seaside Court Saluda River Club Lexington, SC /18/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks sufficient documentation to verify the basis of the claim. The claim should be estimated at zero dollars. 4. Canty, Odell Odell Canty 1990 Durham place road Winnsboro, SC 29180, United States 8/29/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks sufficient documentation to verify the basis of the claim. The claim should be estimated at zero dollars. 5. Case Design Corp Fiberbilt Cases Case Design Corp Fiberbilt Cases 333 School Ln. Telford, PA /30/ Undetermined $0.00 $0.00 Claim is an admittedly protective claim. Furthermore, claim lacks sufficient documentation to verify the basis of the claim. Claim should be estimated at zero dollars. 6. Chandler, Broderick R. Chandler Broderick R. 811 Polo Road Apt 615 Columbia, SC /17/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks sufficient documentation to verify the basis of the claim. The claim should be estimated at zero dollars. 7. Creech, Herman Creech, Herman 214 Park Lane Winnesboro, SC /24/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks sufficient documentation to verify the basis of the claim. The claim should be estimated at zero dollars. 8. Department of Taxation, State of Hawaii Department of Taxation, State of Hawaii, PO Box 259 Honolulu, HI Department of Taxation, State of Hawaii Department of Taxation, State of Hawaii, PO Box 259 Honolulu, HI WECTEC Global Project SVCS Inc. Stone & Webster Construction Inc. 9/18/ Undetermined $0.00 $0.00 Debtors informed movants that they reviewed books and records and the claim seeks an unliquidated amount for which the Debtors are not liable. Furthermore, claim lacks sufficient documentation to verify the basis for any unliquidated amount. 9/18/ Undetermined $0.00 $0.00 Debtors informed movants that they reviewed books and records and the claim seeks an unliquidated amount for which the Debtors are not liable. Furthermore, claim lacks sufficient documentation to verify the basis for any unliquidated amount. 9359/ CURRENT/ v1 11/08/2018 6:58 PM9359/ CURRENT/ v2 11/09/2018 2:09 PM

30 Claimant Name Claimant Address Debtor Name Filed Date Claim to be Estimated Unsecured Unliquidated Amount Sought* Estimated Unsecured Unliquidated Amount Maximum Limitation Ground(s) for Objection to Unliquidated Claim 10. Department of Taxation, State of Hawaii Department of Taxation, State of Hawaii PO Box 259 Honolulu, HI Stone & Webster Asia Inc. 9/18/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks 8. Fairbanks 1 Morse, LLC 1. Fairbanks Morse, LLC 101 N. Tryon Street, Suite 1900 Charlotte, N.C /29/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim does not include sufficient documentation to verify the basis for any unliquidated amount. 9. Franchise Tax Board Franchise Tax Board PO Box 2952 Sacramento, CA WEC Engineering Services Inc. 9/6/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks 10. Franchise Tax Board Franchise Tax Board PO Box 2952 Sacramento, CA PaR Nuclear, Inc. 11/7/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks 11. Franchise Tax Board Franchise Tax Board PO Box 2952 Sacramento, CA WEC Carolina Energy Solutions, Inc. 11/7/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks 12. Franchise Tax Board Franchise Tax Board PO Box 2952 Sacramento, CA Franchise Tax Board Franchise Tax Board PO Box 2952 Sacramento, CA WEC EngineeringTSB Nuclear Energy Services Inc. TSB Nuclear Services Inc. PaR Nuclear,WEC Engineering Services Inc. 911/67/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks 11/7/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks 14. Franchise Tax Board Franchise Tax Board PO Box 2952 Sacramento, CA WEC Carolina Energy Solutions, Inc. 11/7/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks 15. Franchise Tax Board Franchise Tax Board PO Box 2952 Sacramento, CA TSB Nuclear Energy Services Inc. TSB Nuclear Services Inc. 11/7/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks / CURRENT/ v1 11/08/2018 6:58 PM9359/ CURRENT/ v2 11/09/2018 2:09 PM

31 Claimant Name Claimant Address Debtor Name Filed Date Claim to be Estimated Unsecured Unliquidated Amount Sought* Estimated Unsecured Unliquidated Amount Maximum Limitation Ground(s) for Objection to Unliquidated Claim 16. Franchise Tax Board Franchise Tax Board PO Box 2952 Sacramento, CA WEC Engineering Services Inc. 11/7/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks 14. Hecht, 1 Michael 7. Hecht, Michael 252 Tillbrook Road Irwin, PA /29/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks sufficient documentation to verify the basis of the claim. The claim should be estimated at zero dollars. 15. IL Dep t 1 of Revenue - Bankruptcy Section 8. IL Dept of Revenue - Bankruptcy Section PO Box Springfield, IL, United States Stone & Webster Services LLC 8/3/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks 16. Miller, 1 Robert 9. Miller, Robert 2500 Bay Point Dr. Osage Beach, MO /13/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks sufficient documentation to verify the basis of the claim. The claim should be estimated at zero dollars. 20. Mississippi Department of Revenue Mississippi Department of Revenue Bankruptcy Section Post Office Box Jackson, MS, Mississippi Department of Revenue Mississippi Department of Revenue Bankruptcy Section Post Office Box Jackson, MS Mississippi Department of Revenue Mississippi Department of Revenue Bankruptcy Section Post Office Box Jackson, MS Mississippi Department of Revenue Mississippi Department of Revenue Bankruptcy Section Post Office Box Jackson, MS Mississippi Department of Revenue Mississippi Department of Revenue Bankruptcy Section P.O. Box Jackson, MS Shaw Nuclear Services, Inc. WECTEC Global Project Services Inc. WECTEC Contractors Inc. Stone & Webster Construction Inc. Stone & Webster Construction Inc. 9/25/ Undetermined $0.00 $0.00 Claim is admittedly protective claim. Furthermore, claim lacks 9/25/ Undetermined $0.00 $0.00 Claim is admittedly protective claim. Furthermore, claim lacks 9/25/ Undetermined $0.00 $0.00 Claim is admittedly protective claim. Furthermore, claim lacks 9/25/ Undetermined $0.00 $0.00 Claim is admittedly protective claim. Furthermore, claim lacks 8/27/ Undetermined $0.00 $0.00 Claim is admittedly protective claim. Furthermore, claim lacks / CURRENT/ v1 11/08/2018 6:58 PM9359/ CURRENT/ v2 11/09/2018 2:09 PM

32 Claimant Name Claimant Address Debtor Name Filed Date Claim to be Estimated Unsecured Unliquidated Amount Sought* Estimated Unsecured Unliquidated Amount Maximum Limitation Ground(s) for Objection to Unliquidated Claim 25. Mississippi Department of Revenue Mississippi Department of Revenue Bankruptcy Section P.O. Box Jackson, MS PaR Nuclear, Inc. 8/27/ Undetermined $0.00 $0.00 Claim is admittedly protective claim. Furthermore, claim lacks 26. Mississippi Department of Revenue Mississippi Department of Revenue Bankruptcy Section P.O. Box Jackson, MS Mississippi Department of Revenue Mississippi Department of Revenue Bankruptcy Section P.O. Box Jackson, MS Mississippi Department of Revenue Mississippi Department of Revenue Bankruptcy Section P.O. Box Jackson, MS WECTEC Contractors Inc. WECTEC Global Project Services Inc. TSB Nuclear Energy Services Inc. 8/27/ Undetermined $0.00 $0.00 Claim is admittedly protective claim. Furthermore, claim lacks 8/27/ Undetermined $0.00 $0.00 Claim is admittedly protective claim. Furthermore, claim lacks 8/27/ Undetermined $0.00 $0.00 Claim is admittedly protective claim. Furthermore, claim lacks 17. Moran, 2 Marcus J. 9. Marcus J. Moran 175 Bently Dr. Forsyth, GA /27/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks sufficient documentation to verify the basis for any unliquidated amount. 18. NextEra 3 Energy Duane Arnold, LLC NextEra 3 Energy Point Beach, LLC NextEra 3 Energy Seabrook, LLC 2. NextEra Energy Duane Arnold, LLC Rachel Budke 700 Universe Blvd Law Department Juno Beach, Florida 33408, USA NextEra Energy Duane Arnold, LLC Rachel Budke 700 Universe Blvd Law Department Juno Beach, Florida 33408, USA NextEra Energy Seabrook, LLC Rachel Budke 700 Universe Blvd Law Department Juno Beach, Florida 33408, USA 9/1/ Undetermined $0.00 $0.00 Claim lacks sufficient documentation to verify the basis of the unliquidated amount. 9/1/ Undetermined $0.00 $0.00 Claim lacks sufficient documentation to verify the basis of the unliquidated amount. 9/1/ Undetermined $0.00 $0.00 Claim lacks sufficient documentation to verify the basis of the unliquidated amount. 21. Ott, 3Howard 3. Howard Ott 1261 Ott Farm Lane Apollo, PA /15/ Undetermined $0.00 $0.00 Claim is apparently protective. Furthermore, claim lacks sufficient documentation to verify the basis of the claim. The claim should be estimated at zero dollars. * Undetermined means the proof of claim either did not state the dollar amount of the claim or stated that such amount was unknown / CURRENT/ v1 11/08/2018 6:58 PM9359/ CURRENT/ v2 11/09/2018 2:09 PM

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34 Document comparison by Workshare Compare on Friday, November 9, :13:00 PM Input: Document 1 ID Description Document 2 ID Description Rendering set Legend: Insertion Deletion Moved from Moved to Style change Format change Moved deletion Inserted cell Deleted cell Moved cell Split/Merged cell Padding cell Statistics: interwovensite://dms/current/ /1 # v1<CURRENT> - Estimation Mtn 1_Sch 2_Fully Unliq Claims interwovensite://dms/current/ /2 # v2<CURRENT> - Estimation Mtn 1_Sch 2_Fully Unliq Claims Standard Count Insertions 44 Deletions 197 Moved from 11