Case MBK Doc 1031 Filed 01/27/17 Entered 01/27/17 15:47:13 Desc Main Document Page 1 of 3

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1 Case MBK Doc 1031 Filed 01/27/17 Entered 01/27/17 15:47:13 Desc Main Document Page 1 of 3 Gellert Scali Busenkell & Brown, LLC Ronald S. Gellert, Esq. NJ ID # Brya M. Keilson, Esq. NJ ID # North Orange Street, Ste. 300 Wilmington, DE Telephone: (302) Fax: (302) rgellert@gsbblaw.com ASK LLP Joseph L. Steinfeld, Jr., Esq. (admitted pro hac vice) Kara E. Casteel, Esq. (admitted pro hac vice) 2600 Eagan Woods Drive, Suite 400 St. Paul, MN Telephone: (651) Fax: (651) kcasteel@askllp.com Special Counsel to the Official Committee of Unsecured Creditors of Kid Brands, Inc. et al. UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF NEW JERSEY In re: Kid Brands, Inc., et al. Chapter 11 Case No (MBK) Debtors. 1 (Jointly Administered) PLAINTIFF S NOTICE OF PROPOSED SETTLEMENT OF PREFERENCE CLAIM CONTROVERSIES PURSUANT TO SETTLEMENT PROCEDURES ORDER Plaintiff, the Official Committee of Unsecured Creditors of Kid Brands, Inc. et al. (the Committee or Plaintiff ), by and through its undersigned attorneys, hereby files this Notice of Proposed Settlement of Preference Claim Controversies Pursuant to Settlement Procedures Order (the Notice ) pursuant to the Order Granting Motion for Authority to Settle Classes of 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s tax identification number, are: Kid Brands, Inc. (5337); Kids Line, LLC (0448); Sassy, Inc. (9722); I & J Holdco, Inc. (1543); LaJobi, Inc. (1450); CoCaLo, Inc. (3844); and RB Trademark Holdco, LLC (0611).

2 Case MBK Doc 1031 Filed 01/27/17 Entered 01/27/17 15:47:13 Desc Main Document Page 2 of 3 Preference Claim Controversies Pursuant to Bankruptcy Rule 9019(b) and to Modify Compromise Procedures (the Settlement Order ) entered by the Court on September 6, 2016, 2 and avers as follows: 1. Commencing on or about June 16, 2016 Plaintiff filed adversary proceedings against certain defendants for the avoidance of certain transfers pursuant to sections 547, 548, 549 and 502 and Recovery of Property Pursuant to 550 of title 11 of the United States Code (the Avoidance Actions ). 2. Pursuant to the Settlement Order, Avoidance Actions which have a Net Preference Claim 3 less than $500, are subject to noticing procedures (the Noticing Procedures ). Under the Noticing Procedures set forth in the Settlement Order, Plaintiff shall file notices of settlement on an omnibus basis listing the adversary proceeding number, defendant, total amount sought in the complaint, and settlement amount. Electronic filing on those parties who have filed notices of appearance in the Case and therefore receive ECF notifications shall be deemed sufficient service, and negative noticing procedures shall apply. [See D.I. 957.] 3. The Plaintiff has negotiated proposed settlements of certain Avoidance Actions identified on Exhibit A attached hereto. Exhibit A contains the name of each such defendant (the Defendant or Defendants ), the total transfers amount sought in the complaint against each Defendant, and the amount paid or to be paid by each Defendant to Plaintiff in settlement of the Avoidance Action (the Proposed Settlement ). 4. For each Proposed Settlement identified on Exhibit A, Plaintiff believes that the Proposed Settlement in the adversary proceeding is in the best interest of the creditors when taking into account the efficacy of the defenses raised by the respective Defendant. Additionally, given the known costs of further pursuing these matters, Plaintiff has determined that the net 2 D.I All terms not defined herein shall have the meanings ascribed to them in either the Motion for Authority to Settle Classes of Preference Claim Controversies Pursuant to Bankruptcy Rule 9019(b) and to Modify Compromise Procedures [D.I. 943] or the Settlement Order [D.I. 957]. 2

3 Case MBK Doc 1031 Filed 01/27/17 Entered 01/27/17 15:47:13 Desc Main Document Page 3 of 3 result to creditors would be greater through the Proposed Settlement than through further litigation. 5. Notice of the Proposed Settlements has been provided to the parties designated in the Settlement Order. 6. Absent any objections on or before fourteen (14) days from the date of this Notice, the settlements listed on Exhibit A shall be deemed approved without any further action of the Plaintiff or Court. Dated: January 25, 2017 By: /s/ Ronald S. Gellert Ronald S. Gellert, Esq. Brya M. Keilson, Esq. Gellert Scali Busenkell & Brown, LLC 1201 North Orange Street, Ste. 300 Wilmington, DE Telephone: (302) Fax: (302) rgellert@gsbblaw.com Joseph L. Steinfeld, Jr., DC SBN , MN SBN , VA SBN Kara E. Casteel, MN SBN ASK LLP 2600 Eagan Woods Drive, Suite 400 St. Paul, MN Telephone: (651) ext. 846 Fax: (651) kcasteel@askllp.com Edward E. Neiger, Esq. 151 West 46th Street, 4th Fl. New York, NY Telephone: (212) Fax: (212) Special Counsel to the Official Committee of Unsecured Creditors of Kid Brands, Inc., et al. 3

4 Case MBK Doc Filed 01/27/17 Entered 01/27/17 15:47:13 Desc Exhibit A Page 1 of 3 Exhibit A

5 Case MBK Doc Filed 01/27/17 Entered 01/27/17 15:47:13 Desc Exhibit A Page 2 of 3 Schedule of Settlement Subject for Approval Defendant Adversary Number Total Transfers Settlement Amount Comment ADK Sales, Inc $22, $2, Amwan Inc $200, $20, Defendant asserted an inability to pay the full liability due to financial hardship. Plaintiff has reviewed financial information provided and in an exercise of business judgment is satisfied that the settlement reached is appropriate given the financial considerations. Oppenheimer & Co., Inc $90, $40, Newell Rubbermaid Inc $544, $70, NDO America, Inc $30, $17,512.39

6 Case MBK Doc Filed 01/27/17 Entered 01/27/17 15:47:13 Desc Exhibit A Page 3 of 3 San Diego Personnel & Employment Agency, Inc $42, $31, Serta, Inc $49, $2, Yantai Pacific Home Fashion Co. Ltd $663, $74,987.00

7 Case MBK Doc Filed 01/27/17 Entered 01/27/17 15:47:13 Desc Certificate of Service Page 1 of 2 Gellert Scali Busenkell & Brown, LLC Ronald S. Gellert, Esq. NJ ID # Brya M. Keilson, Esq. NJ ID # North Orange Street, Ste. 300 Wilmington, DE Telephone: (302) Fax: (302) rgellert@gsbblaw.com ASK LLP Joseph L. Steinfeld, Jr. (admitted pro hac vice) Kara E. Casteel, Esq. (admitted pro hac vice) 2600 Eagan Woods Drive, Suite 400 St. Paul, MN Telephone: (651) Fax: (651) kcasteel@askllp.com Special Counsel to the Official Committee of Unsecured Creditors of Kid Brands, Inc. et al. UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF NEW JERSEY In re: Kid Brands, Inc., et al. Chapter 11 Case No (MBK) Debtors. 1 (Jointly Administered) CERTIFICATE OF SERVICE I, Kara E. Casteel, hereby certify that on January 25, 2017, a copy of Plaintiff s Notice Of Proposed Settlement of Preference Claim Controversies Pursuant To Settlement Procedures Order was caused to be served via the Court s Electronic Filing System to those 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s tax identification number, are: Kid Brands, Inc. (5337); Kids Line, LLC (0448); Sassy, Inc. (9722); I & J Holdco, Inc. (1543); LaJobi, Inc. (1450); CoCaLo, Inc. (3844); and RB Trademark Holdco, LLC (0611).

8 Case MBK Doc Filed 01/27/17 Entered 01/27/17 15:47:13 Desc Certificate of Service Page 2 of 2 parties who have filed notices of appearance in the Case, which notice is sufficient pursuant to the Order Granting Motion for Authority to Settle Classes of Preference Claim Controversies Pursuant to Bankruptcy Rule 9019(b) and to Modify Compromise Procedures entered by the Court on September 6, 2016 as D.I Dated: January 25, 2017 By: /s/ Kara E. Casteel Joseph L. Steinfeld, Jr., DC SBN , MN SBN , VA SBN Kara E. Casteel, MN SBN ASK LLP 2600 Eagan Woods Drive, Suite 400 St. Paul, MN Telephone: (651) ext. 846 Fax: (651) kcasteel@askllp.com Edward E. Neiger, Esq. 151 West 46th Street, 4th Fl. New York, NY Telephone: (212) Fax: (212) Ronald S. Gellert, Esq. Brya M. Keilson, Esq. Gellert Scali Busenkell & Brown, LLC 1201 North Orange Street, Ste. 300 Wilmington, DE Telephone: (302) Fax: (302) rgellert@gsbblaw.com Special Counsel to the Official Committee of Unsecured Creditors of Kid Brands, Inc., et al. 2