Case KG Doc 776 Filed 06/14/16 Page 1 of 9 UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE

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1 Case KG Doc 776 Filed 06/14/16 Page 1 of 9 UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE In re: MALIBU LIGHTING CORPORATION, et al., Debtors. Chapter 11 Case No KG Jointly Administered Related Docket No. 588 CERTIFICATION OF COUNSEL REGARDING ORDER APPROVING AMENDMENT TO STIPULATION MODIFYING THE AUTOMATIC STAY TO PERMIT LIQUIDATION AND RESOLUTION OF CLAIM OF KELLY RIPKEN I, Elihu E. Allinson III of Sullivan Hazeltine Allinson LLC, local counsel for Continental Insurance Company and Columbia Casualty Company and their North American affiliates using the CNA service mark (collectively, the CNA Insurance Companies or CNA ), hereby certifies as follows. 1. On October 8, 2015, (the Petition Date ), each of the above-captioned Debtors (the Debtors ) filed a voluntary petition for relief under Chapter 11 of Title 11 of the United States Code (the Bankruptcy Code ) in the United States Bankruptcy Court for the District of Delaware (the Court ). 2. The CNA Insurance Companies issued certain insurance policies, including a general liability policy (the Insurance Policies ) to the Debtors prior to the commencement of these chapter 11 proceedings. 3. On February 9, 2016, Claimant Mrs. Kelly Ripken ( Movant or Mrs. Ripken, and together with CNA, the Parties ) filed a Motion for Relief from Automatic Stay [Docket No. 445] (the Stay Relief Motion ) in order to pursue her alleged personal injury claim (the

2 Case KG Doc 776 Filed 06/14/16 Page 2 of 9 Claim ) 1, and to collect on that Claim from one of the Insurance Policies allegedly covering the claim. 4. On February 23, 2016, CNA filed its Limited Objection to the Stay Relief Motion [Docket No. 480] (the Limited Objection ) requesting, inter alia, that the Stay Relief Motion be held in abeyance while the Parties explore alternative dispute resolution options in light of the many similarly situated claims likely to arise over the course of the Debtors bankruptcy case. 5. In an effort to resolve the Stay Relief Motion and the Limited Objection, the Parties engaged in good faith negotiations and reached an agreement to modify the automatic stay in accordance with the terms and conditions set forth in the Stipulation Modifying the Automatic Stay to Permit Liquidation and Resolution of the Claim of Kelly Ripken [Docket No ] (the Stipulation ). The Stipulation provides a procedural framework for resolving Mrs. Ripken s personal injury claim. On April 5, 2016, the Court entered an Order approving the Stipulation [Docket No. 588]. 6. Paragraph 2 of the Stipulation provides If, within sixty (60) days (or such later date to which Mrs. Ripken and CNA may further stipulate) of the entry of an order by the Bankruptcy Court approving this Stipulation, Mrs. Ripken s personal injury claim has not been resolved and/or settled, the Claim shall be referred to non-binding mediation. 7. The Parties anticipate engaging in productive settlement negotiations and believe it may be possible to resolve Mrs. Ripken s Claim without incurring the expense of entering into non-binding mediation. 1 On February 8, 2016, Mrs. Ripken timely filed a proof of claim in this proceeding on account of the Claim, which proof of claim was assigned No. 194 on the register of claims for this proceeding.

3 Case KG Doc 776 Filed 06/14/16 Page 3 of 9 8. Thus, as contemplated by Paragraph 2 of the Stipulation, the Parties have stipulated and agreed to amend the Stipulation by extending the date upon which Mrs. Ripken s Claim shall be referred to non-binding mediation to June 17, WHEREFORE, CNA respectfully requests that this Honorable Court enter the Proposed Order attached hereto as Exhibit A approving the Amendment. Date: June 14, 2016 Wilmington, DE SULLIVAN HAZELTINE ALLINSON LLC /s/ E.E. Allinson III William D. Sullivan (No. 2820) William A. Hazeltine (No. 3294) Elihu E. Allinson III (No. 3476) 901 North Market Street, Suite 1300 Wilmington, DE Tel: (302) Fax: (302) and - Jonathan W. Young, Esq. Michael B. Kind Locke Lord LLP 111 South Wacker Drive Chicago, IL Tel: (312) Fax: (855) Counsel to Continental Insurance Company and Columbia Casualty Company and their North American affiliates using the CNA service mark

4 Case KG Doc 776 Filed 06/14/16 Page 4 of 9 Exhibit A Proposed Order

5 Case KG Doc 776 Filed 06/14/16 Page 5 of 9 UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE In re: MALIBU LIGHTING CORPORATION, et al., Debtors. Chapter 11 Case No KG Jointly Administered Related Docket No. 588 ORDER APPROVING AMENDMENT TO STIPULATION MODIFYING THE AUTOMATIC STAY TO PERMIT LIQUIDATION AND RESOLUTION OF CLAIM OF KELLY RIPKEN Upon consideration of the Amendment to Stipulation Modifying the Automatic Stay to Permit Liquidation and Resolution of the Claim of Kelly Ripken (the Amendment ); the Court having determined that good and adequate cause exists for approval of the Amendment; and the Court having determined that no further notice of the Amendment is necessary; IT IS HEREBY ORDERED THAT 1. The Amendment attached hereto as Exhibit 1 is APPROVED. 2. The terms of the Amendment are incorporated in full as if set forth herein. 3. This Court shall retain jurisdiction to hear and determine all matters arising from or relating to the implementation, interpretation, and enforcement of this Order. Dated: June, 2016 THE HONORABLE KEVIN GROSS UNITED STATES BANKRUPTCY JUDGE

6 Case KG Doc 776 Filed 06/14/16 Page 6 of 9 Exhibit 1 Stipulation

7 Case KG Doc 776 Filed 06/14/16 Page 7 of 9 UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE In re: MALIBU LIGHTING CORPORATION, et al., Debtors. Chapter 11 Case No KG Jointly Administered Related Docket No. 588 AMENDMENT TO STIPULATION MODIFYING THE AUTOMATIC STAY TO PERMIT LIQUIDATION AND RESOLUTION OF CLAIM OF KELLY RIPKEN IT IS HEREBY STIPULATED AND AGREED between Claimant Kelly Ripken (the Movant or Mrs. Ripken ) and Continental Insurance Company and Columbia Casualty Company and their North American affiliates using the CNA service mark (collectively, the CNA Insurance Companies or CNA, and together with Mrs. Ripken, the Parties ), that the date upon which Mrs. Ripken s personal injury claim shall be referred to non-binding mediation, as set forth in Paragraph 2 of the Stipulation, is extended to June 17, [concluded on the following page]

8 Case KG Doc 776 Filed 06/14/16 Page 8 of 9 This Amendment may be executed in any number of counterparts and by facsimile or electronic transmission, each of which shall be an original, with the same effect as if the signatures hereto were upon the same document. AGREED TO: Dated: June, 2016 /s/ E.E. Allinson III SULLIVAN HAZELTINE ALLINSON LLC Elihu Ezekiel Zeke Allinson III, Esq. 901 North Market Street, Suite 1300 Wilmington, Delaware Telephone: Facsimile: zallinson@sha-llc.com - and - LOCKE LORD LLP Jonathan W. Young Michael B. Kind 111 South Wacker Drive Chicago, Illinois Telephone: Facsimile: jonathan.young@lockelord.com michael.kind@lockelord.com Attorneys for Continental Casualty Company /s/ PACHULSKI STANG ZIEHL & JONES LLP Jeffrey N. Pomerantz (CA Bar No ) Maxim B. Litvak (CA Bar No ) James O Neill (DE Bar No. 4042) 919 North Market Street, 17th Floor; P.O. Box 8705 Wilmington, Delaware Telephone: Facsimile: jpomerantz@pszjlaw.com mlitvak@pszjlaw.com mseidl@pszjlaw.com /s/ Christopher M. Samis WHITEFORD, TAYLOR, & PRESTON LLC Christopher M. Samis L. Katherine Good Chantelle D. McClamb The Renaissance Centre, Suite North King Street Wilmington, DE Telephone: csamis@wtplaw.com kgood@wtplaw.com cmcclamb@wtp.com - and - SHAPIRO SHER GUINOT & SANDLER Paul Mark Sandler Eric R. Harlan Shapiro Sher Guinot & Sandler 250 West Pratt Street Baltimore, MD Telephone: pms@shapirosher.com erh@shapirosher.com Attorneys for Kelly Ripken Attorneys for the Debtors

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10 Case KG Doc Filed 06/14/16 Page 1 of 2 Exhibit A Proposed Order

11 Case KG Doc Filed 06/14/16 Page 2 of 2 UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE In re: MALIBU LIGHTING CORPORATION, et al., Debtors. Chapter 11 Case No KG Jointly Administered Related Docket No. 588 ORDER APPROVING AMENDMENT TO STIPULATION MODIFYING THE AUTOMATIC STAY TO PERMIT LIQUIDATION AND RESOLUTION OF CLAIM OF KELLY RIPKEN Upon consideration of the Amendment to Stipulation Modifying the Automatic Stay to Permit Liquidation and Resolution of the Claim of Kelly Ripken (the Amendment ); the Court having determined that good and adequate cause exists for approval of the Amendment; and the Court having determined that no further notice of the Amendment is necessary; IT IS HEREBY ORDERED THAT 1. The Amendment attached hereto as Exhibit 1 is APPROVED. 2. The terms of the Amendment are incorporated in full as if set forth herein. 3. This Court shall retain jurisdiction to hear and determine all matters arising from or relating to the implementation, interpretation, and enforcement of this Order. Dated: June, 2016 THE HONORABLE KEVIN GROSS UNITED STATES BANKRUPTCY JUDGE

12 Case KG Doc Filed 06/14/16 Page 1 of 4 Exhibit 1 Stipulation

13 Case KG Doc Filed 06/14/16 Page 2 of 4 UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE In re: MALIBU LIGHTING CORPORATION, et al., Debtors. Chapter 11 Case No KG Jointly Administered Related Docket No. 588 AMENDMENT TO STIPULATION MODIFYING THE AUTOMATIC STAY TO PERMIT LIQUIDATION AND RESOLUTION OF CLAIM OF KELLY RIPKEN IT IS HEREBY STIPULATED AND AGREED between Claimant Kelly Ripken (the Movant or Mrs. Ripken ) and Continental Insurance Company and Columbia Casualty Company and their North American affiliates using the CNA service mark (collectively, the CNA Insurance Companies or CNA, and together with Mrs. Ripken, the Parties ), that the date upon which Mrs. Ripken s personal injury claim shall be referred to non-binding mediation, as set forth in Paragraph 2 of the Stipulation, is extended to June 17, [concluded on the following page]

14 Case KG Doc Filed 06/14/16 Page 3 of 4 This Amendment may be executed in any number of counterparts and by facsimile or electronic transmission, each of which shall be an original, with the same effect as if the signatures hereto were upon the same document. AGREED TO: Dated: June 14, 2016 /s/ E.E. Allinson III SULLIVAN HAZELTINE ALLINSON LLC Elihu Ezekiel Zeke Allinson III, Esq. 901 North Market Street, Suite 1300 Wilmington, Delaware Telephone: Facsimile: zallinson@sha-llc.com - and - LOCKE LORD LLP Jonathan W. Young Michael B. Kind 111 South Wacker Drive Chicago, Illinois Telephone: Facsimile: jonathan.young@lockelord.com michael.kind@lockelord.com Attorneys for Continental Casualty Company /s/ James O Neill PACHULSKI STANG ZIEHL & JONES LLP Jeffrey N. Pomerantz (CA Bar No ) Maxim B. Litvak (CA Bar No ) James O Neill (DE Bar No. 4042) 919 North Market Street, 17th Floor; P.O. Box 8705 Wilmington, Delaware Telephone: Facsimile: jpomerantz@pszjlaw.com mlitvak@pszjlaw.com mseidl@pszjlaw.com /s/ Christopher M. Samis WHITEFORD, TAYLOR, & PRESTON LLC Christopher M. Samis L. Katherine Good Chantelle D. McClamb The Renaissance Centre, Suite North King Street Wilmington, DE Telephone: csamis@wtplaw.com kgood@wtplaw.com cmcclamb@wtp.com - and - SHAPIRO SHER GUINOT & SANDLER Paul Mark Sandler Eric R. Harlan Shapiro Sher Guinot & Sandler 250 West Pratt Street Baltimore, MD Telephone: pms@shapirosher.com erh@shapirosher.com Attorneys for Kelly Ripken Attorneys for the Debtors

15 Case KG Doc Filed 06/14/16 Page 4 of 4