Case KG Doc 3496 Filed 08/05/13 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE.

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1 Case KG Doc 3496 Filed 08/05/13 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: NEWPAGE CORPORATION, et al., Debtors. x Chapter 11 (KG) Jointly Administered Ref. Docket No CERTIFICATION OF COUNSEL REGARDING ORDER SUSTAINING THIRTY- FOURTH OMNIBUS (SUBSTANTIVE) OBJECTION TO (I) DUPLICATE CLAIMS, (II) OVERSTATED CLAIMS AND (III) NO LIABILITY CLAIMS BY LITIGATION TRUSTEE PURSUANT TO SECTION 502(B) OF THE BANKRUPTCY CODE, BANKRUPTCY RULES 3003 AND 3007, AND LOCAL RULE On July 9, 2013, PIRINATE Consulting Group, LLC, the Litigation Trustee of the NP Creditor Litigation Trust (the Litigation Trustee ) filed the Thirty-Fourth Omnibus (Substantive) Objection to (I) Duplicate Claims, (II) Overstated Claims and (III) No Liability Claims by Litigation Trustee Pursuant to Section 502(b) of the Bankruptcy Code, Bankruptcy Rules 3003 and 3007, and Local Rule [D.I. 3459] (the Objection ). 1 Responses to the Objection were required to be filed on or before July 23, 2013 at 4:00 p.m. (ET) (the Response Deadline ). Prior to the Response Deadline, the Litigation Trustee received an informal response from General Electric International Inc. ( GE, together with the Litigation Trustee, the Parties ) regarding Proof of Claim No ( Claim No ). The Litigation Trustee also received an informal response from Eka Chemicals regarding Proof of Claim No. 2496, which has been resolved. No other responses to the Objection were received by the Response Deadline. 1 Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Objection.

2 Case KG Doc 3496 Filed 08/05/13 Page 2 of 3 A hearing on the Objection is currently scheduled for September 17, 2013 at 10:00 a.m. (ET) (the Hearing ). In advance of the Hearing, the Parties will continue to work together in an effort to reach a consensual resolution. At this time, however, the Litigation Trustee seeks entry of a revised form of order (the Revised Order ), sustaining the Objection with respect to all claims other than Claim No Accordingly, the Litigation Trustee has removed Claim No from Exhibit B attached to the Revised Order attached hereto as Exhibit I. For the convenience of the Court, a blackline of Exhibit B attached to the proposed order filed with the Objection compared to Exhibit B attached to the Revised Order is attached hereto as Exhibit II. WHEREFORE, the Litigation Trustee respectfully requests that the Court enter the Revised Order at the Court s earliest convenience without further notice or hearing. Dated: Wilmington, Delaware August 5, 2013 YOUNG CONAWAY STARGATT & TAYLOR, LLP /s/ Andrew L. Magaziner M. Blake Cleary (No. 3614) Jaime Luton Chapman (No. 4936) Andrew L. Magaziner (No. 5426) Rodney Square 1000 North King Street Wilmington, Delaware Telephone: (302) Facsimile: (302) and- 2

3 Case KG Doc 3496 Filed 08/05/13 Page 3 of 3 PAUL HASTINGS LLP Luc A. Despins Robert E. Winter Christopher Fong Park Avenue Tower 75 East 55th Street, First Floor New York, New York Telephone: (212) Facsimile: (212) Co-Counsel to the Litigation Trustee 3

4 Case KG Doc Filed 08/05/13 Page 1 of 12 Exhibit I Revised Order

5 Case KG Doc Filed 08/05/13 Page 2 of 12 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: NEWPAGE CORPORATION, et al., Reorganized Debtors. Chapter 11 (KG) Jointly Administered Ref. Docket No and ORDER SUSTAINING THIRTY-FOURTH OMNIBUS (SUBSTANTIVE) OBJECTION TO (I) DUPLICATE CLAIMS, (II) OVERSTATED CLAIMS AND (III) NO LIABILITY CLAIMS BY LITIGATION TRUSTEE PURSUANT TO SECTION 502(b) OF THE BANKRUPTCY CODE, BANKRUPTCY RULES 3003 AND 3007, AND LOCAL RULE Upon consideration of the Thirty-Fourth Omnibus (Substantive) Objection (the Objection ) of PIRINATE Consulting Group, LLC, the Litigation Trustee of the NP Creditor Litigation Trust (the Litigation Trustee ) appointed in the chapter 11 cases of NewPage Corporation and its affiliated reorganized debtors, by which the Litigation Trustee respectfully requests the entry of an order pursuant to section 502(b) of title 11 of the United States Code (the Bankruptcy Code ), Rules 3003 and 3007 of the Federal Rules of Bankruptcy Procedure, and Rule of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware, disallowing, reducing, or otherwise modifying each of the Claims 1 identified on Exhibits A-C hereto; and it appearing that the Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334; and that due and adequate notice of the Objection having been given under the circumstances; and sufficient cause appearing thereof; it is hereby ORDERED that: 1 Capitalized terms not otherwise defined herein shall have the meaning ascribed to such terms in the Objection.

6 Case KG Doc Filed 08/05/13 Page 3 of The Objection is sustained. 2. The Duplicate Claims listed on Exhibit A are hereby disallowed in their entirety. 3. The Overstated Claims listed on Exhibit B are hereby fixed in the amount listed in the column titled Modified Amount on Exhibit B. 4. The No Liability Claims listed on Exhibit C are hereby disallowed in their entirety. 5. The Litigation Trustee s right to amend, modify or supplement the Objection, and to file additional objections to any claims filed in these chapter 11 cases including, without limitation, the claims that are the subject of the Objection, are fully reserved. The Litigation Trustee s right to commence additional proceedings with respect to the claims that are subject to the Objection, including but not limited to proceedings under sections 502(d), 510, 542, 543, 544, 545, 547, 548, 549, 550, 551 and 553 of the Bankruptcy Code, is also fully reserved. 6. The Litigation Trustee s right to object to any of the Claims on any grounds in future omnibus objections to claims is fully reserved. Nothing herein, including the resolution of the Objection as to any particular claim that is the subject of the Objection, shall have any effect on any additional proceedings, including but not limited to proceedings under sections 502(d), 510, 542, 543, 544, 545, 547, 548, 549, 550, 551 and 553 of the Bankruptcy Code, that have been, or will be, commenced with respect to the claims that are subject to the Objection. 2

7 Case KG Doc Filed 08/05/13 Page 4 of 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: Wilmington, Delaware, 2013 HONORABLE KEVIN GROSS CHIEF UNITED STATES BANKRUPTCY JUDGE 3

8 Case KG Doc Filed 08/05/13 Page 5 of 12 EXHIBIT A DUPLICATE CLAIMS

9 Case KG Doc Filed 08/05/13 Page 6 of 12 Exhibit A THIRTY-FOURTH OMNIBUS OBJECTION DUPLICATE CLAIMS Claims to be Expunged Remaining Claims Name/Address of Claimant Claim Number Date Filed Case Information Name/Address of Claimant Claim Number Date Filed Case Info Bass Maintenance Corp. c/o Rory Toombs P.O. Box 98 Wickliffe, KY /30/2012 Case No Wickliffe Paper Company LLC Bass Maintenance Corp. c/o Rory Toombs P.O. Box 98 Wickliffe, KY /30/2012 Collier Electric, Inc. Mark C. Whitlow Esq. P.O. Box 995 Paducah, KY /13/2012 Collier Electric Inc. Mark C. Whitlow Esq. P.O. Box 995 Paducah, KY /27/2012 Imerys Talc America, Inc. fka Luzenac America Inc. Attn: Fred Panion 767 Old Yellowstone Trail Three Forks, MT /30/2012 Imerys Talc America, Inc. fka Luzenac America Inc. Attn: Fred Panion 767 Old Yellowstone Trail Three Forks, MT /30/2012 Case No Rumford Paper Company Imerys Talc America, Inc. fka Luzenac America Inc. Attn: Fred Panion 767 Old Yellowstone Trail Three Forks, MT /30/2012 Case No Wickliffe Paper Company Imerys Talc America, Inc. fka Luzenac America Inc. Attn: Fred Panion 767 Old Yellowstone Trail Three Forks, MT /30/2012 Case No Escanaba Paper Company Imerys Talc America, Inc. fka Luzenac America Inc. Attn: Fred Panion 767 Old Yellowstone Trail Three Forks, MT /30/2012 Case No NewPage Wisconsin System Inc. 1

10 Case KG Doc Filed 08/05/13 Page 7 of 12 Exhibit A THIRTY-FOURTH OMNIBUS OBJECTION DUPLICATE CLAIMS Claims to be Expunged Remaining Claims Name/Address of Claimant Claim Number Date Filed Case Information Name/Address of Claimant Claim Number Date Filed Case Info Imerys Talc Canada, Inc. fka Luzenac Inc. Attn Fred Panion Imerys Talc America, Inc. 767 Old Yellowstone Trail Three Forks, MT /30/2012 Imerys Talc Canada, Inc. Attn Fred Panion Imerys Talc America, Inc. 767 Old Yellowstone Trail Three Forks, MT /30/2012 Case No NewPage Wisconsin System Inc. Olin Corporation c/o Laura F. Ketcham, Esquire Husch Blackwell LLP 736 Georgia Avenue, Suite 300 Chattanooga, TN /02/2012 Case No Rumford Paper Company Olin Corporation c/o Laura F. Ketcham, Esquire Husch Blackwell LLP 736 Georgia Avenue, Suite 300 Chattanooga, TN /2/2012 Case No Rumford Paper Company Olin Corporation c/o Laura F. Ketcham, Esquire Husch Blackwell LLP 736 Georgia Avenue, Suite 300 Chattanooga, TN /02/2012 Case No Wickliffe Paper Company LLC Olin Corporation c/o Laura F. Ketcham, Esquire Husch Blackwell LLP 736 Georgia Avenue, Suite 300 Chattanooga, TN /2/2012 Case No Wickliffe Paper Company Olin Corporation c/o Laura F. Ketcham, Esquire Husch Blackwell LLP 736 Georgia Avenue, Suite 300 Chattanooga, TN /02/2012 Case No Escanaba Paper Company Olin Corporation c/o Laura F. Ketcham, Esquire 736 Georgia Avenue, Suite 300 Chattanooga, TN /2/2012 Case No Escanaba Paper Company Totals: 7 Claims 2

11 Case KG Doc Filed 08/05/13 Page 8 of 12 EXHIBIT B OVERSTATED CLAIMS

12 Case KG Doc Filed 08/05/13 Page 9 of 12 Exhibit B THIRTY-FOURTH OMNIBUS OBJECTION OVERSTATED CLAIMS Overstated Claims Name/Address of Claimant Ershings Inc South Yale #560 Tulsa, OK NMHG Financial Services, Inc. c/o Reed Smith LLP Attn: Ann E. Pille 10 S. Wacker Drive, Suite 4000 Chicago, IL NMHG Financial Services, Inc. c/o Reed Smith LLP Attn: Ann E. Pille 10 S. Wacker Drive, Suite 4000 Chicago, IL NMHG Financial Services, Inc. c/o Reed Smith LLP Attn: Ann E. Pille 10 S. Wacker Drive, Suite 4000 Chicago, IL Claim Number Date Filed Case Information /27/2011 Case No Wickliffe Paper Company LLC Case No NewPage Wisconsin System, Inc Case No NewPage Wisconsin System, Inc. Current Unsecured Modified Amount Reason for Reduction Amount 2 $54, (U) $48, (U) Claim is overstated. Reduction due to credit issued by claimant. $55, (U) $3, (U) Claim contains post-petition amounts paid in ordinary course of business and post-petition fees. $220, (U) $5, (U) Claim contains post-petition amounts paid in ordinary course of business and post-petition fees. $51, (U) $6, (U) Claim contains post-petition amounts paid in ordinary course of business and post-petition fees. 1 Case information reflects prior stipulations and/or orders reassigning the Claims. 2 Current unsecured amounts reflect prior stipulations and/or orders reclassifying, reducing or otherwise modifying the Claims.

13 Case KG Doc Filed 08/05/13 Page 10 of 12 Exhibit B THIRTY-FOURTH OMNIBUS OBJECTION OVERSTATED CLAIMS Name/Address of Claimant NMHG Financial Services, Inc. c/o Reed Smith LLP Attn: Ann E. Pille 10 S. Wacker Drive, Suite 4000 Chicago, IL Classic Color Marc J. Bell, Secretary/Treasurer 2424 S 25TH AVE BROADVIEW, IL Eka Chemicals c/o Mark Moedritzer Shook, Hardy & Bacon L.L.P Grand Blvd. Kansas City, MO Claim Number Date Filed Case Information /3/2012 Case No Luke Paper Company Current Unsecured Modified Amount Reason for Reduction Amount 2 $677, (U) $2, (U) Claim contains post-petition amounts paid in ordinary course of business and post-petition fees. $73, (U) $2, (U) Claim is overstated. Claimant received goods in lieu of payment pursuant to August 26, 2011 agreement between the parties. $37, (U) $16, (U) Claim in case no is overstated. See footnote 1 to Objection. Totals: 8 Claims (U) Unsecured 2

14 Case KG Doc Filed 08/05/13 Page 11 of 12 EXHIBIT C NO LIABILITY CLAIMS

15 Case KG Doc Filed 08/05/13 Page 12 of 12 Exhibit C THIRTY-FOURTH OMNIBUS OBJECTION NO LIABILITY CLAIMS No Liability Claims Name/Address of Claimant Chase Paymentech, LLC Dallas Parkway Building II Dallas, Texas Attn: Lazonia Clark GP Cellulose America Marketing, LLC 133 Peachtree St NE Atlanta, GA News America Marketing Joe DeLallo 20 Westport Rd, 1st Floor Wilton, CT Ronald & Roxanne Sittlow 318 Hillside Cir Baldwin, WI Claim Number Date Filed Case Information /19/ /3/2012 Case No Rumford Paper Company /3/ /11/2012 Total Unsecured Amount Claimed Reason for Disallowance $1.00 (U) Claim is unsupported by Reorganized Debtors Books and Records. Reorganized Debtors do not owe any pre-petition amounts to claimant. $18, (U) Claim is unsupported by Reorganized Debtors Books and Records. Reorganized Debtors do not owe any pre-petition amounts to claimant. $500,000 (U) Claim is unsupported by Reorganized Debtors Books and Records. Reorganized Debtors do not owe any pre-petition amounts to claimant. $1, (U) Claim is unsupported by Reorganized Debtors Books and Records. Reorganized Debtors do not owe any pre-petition amounts to claimant. Totals: 4 Claims (U) Unsecured 1 Case information reflects the effects of any Bankruptcy Court order reassigning the Claim.

16 Case KG Doc Filed 08/05/13 Page 1 of 3 Exhibit II Blackline

17 Case KG Doc Filed 08/05/13 Page 2 of 3 Exhibit B THIRTY-FOURTH OMNIBUS OBJECTION OVERSTATED CLAIMS ` Overstated Claims Name/Address of Claimant Ershings Inc South Yale #560 Tulsa, OK NMHG Financial Services, Inc. c/o Reed Smith LLP Attn: Ann E. Pille 10 S. Wacker Drive, Suite 4000 Chicago, IL NMHG Financial Services, Inc. c/o Reed Smith LLP Attn: Ann E. Pille 10 S. Wacker Drive, Suite 4000 Chicago, IL NMHG Financial Services, Inc. c/o Reed Smith LLP Attn: Ann E. Pille 10 S. Wacker Drive, Suite 4000 Chicago, IL Claim Number Date Filed Case Information /27/2011 Case No Wickliffe Paper Company LLC Case No NewPage Wisconsin System, Inc Case No NewPage Wisconsin System, Inc. Current Unsecured Modified Amount Reason for Reduction Amount 2 $54, (U) $48, (U) Claim is overstated. Reduction due to credit issued by claimant. $55, (U) $3, (U) Claim contains post-petition amounts paid in ordinary course of business and post-petition fees. $220, (U) $5, (U) Claim contains post-petition amounts paid in ordinary course of business and post-petition fees. $51, (U) $6, (U) Claim contains post-petition amounts paid in ordinary course of business and post-petition fees. 1 Case information reflects prior stipulations and/or orders reassigning the Claims. 2 Current unsecured amounts reflect prior stipulations and/or orders reclassifying, reducing or otherwise modifying the Claims.

18 Case KG Doc Filed 08/05/13 Page 3 of 3 Exhibit B THIRTY-FOURTH OMNIBUS OBJECTION OVERSTATED CLAIMS ` NMHG Financial Services, Inc. c/o Reed Smith LLP Attn: Ann E. Pille 10 S. Wacker Drive, Suite 4000 Chicago, IL Classic Color Marc J. Bell, Secretary/Treasurer 2424 S 25TH AVE BROADVIEW, IL General Electric International Inc. c/o Glenn M. Reisman Two Corporate Drive Suite 234 Shelton, CT Eka Chemicals c/o Mark Moedritzer Shook, Hardy & Bacon L.L.P Grand Blvd. Kansas City, MO Totals: /3/2012 Case No Luke Paper Company 8 Claims $677, (U) $2, (U) Claim contains post-petition amounts paid in ordinary course of business and post-petition fees. $73, (U) $2, (U) Claim is overstated. Claimant received goods in lieu of payment pursuant to August 26, 2011 agreement between the parties. $79, (U) $50, (U) Claim contains post-petition amounts to be paid in ordinary course of business. $37, (U) $16, (U) Claim in case no is overstated. See footnote 1 to Objection. (U) Unsecured