HEARING DATE AND TIME January 22, 2019 at 1100 a.m. (Eastern Time) RESPONSE DEADLINE January 15, 2019 at 400 p.m. (Eastern Time) THE ATTACHED OMNIBUS OBJECTION TO CLAIMS SEEKS TO DISALLOW AND EXPUNGE CERTAIN FILED PROOFS OF CLAIM. PLEASE CAREFULLY REVIEW THE ATTACHED OBJECTION AND THE ATTACHMENTS THERETO TO DETERMINE WHETHER THE OBJECTION AFFECTS ANY CLAIM YOU MAY HAVE FILED. IF YOU HAVE QUESTIONS, PLEASE CONTACT NEAL PAUL DONNELLY AT (212) 373-3510 OR NDONNELLY@PAULWEISS.COM. UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------ x In re Chapter 11 WESTINGHOUSE ELECTRIC COMPANY Case No. 17-10751 (MEW) LLC, et al., Debtors. 1 (Jointly Administered) ------------------------------------------------------------ x NOTICE OF TWENTY-FOURTH OMNIBUS OBJECTION TO CLAIMS ( ) PLEASE TAKE NOTICE that on November 30, 2018, Wind Down Co 2 filed the annexed Twenty-Fourth Omnibus Objection to ( ) (the Objection ), pursuant to sections 105(a) 502(b) of title 11 of the United States Code (the Bankruptcy Code ) Rule 3007(d) of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ). A hearing on the relief requested in the Objection has been requested on January 22, 2019 at 1100 a.m. (Eastern Time) (the Hearing ) before the Honorable Michael E. Wiles in the United States Bankruptcy Court for the Southern District of New York, located at One Bowling Green, New York, New York 10004 (the Bankruptcy Court ). 1 On September 25, 2018, many of the Debtors Chapter 11 Cases were closed pursuant to the Court s Order (I) Consolidating the Administration of Certain Remaining Matters at the Lead Case; (II) Entering a Final Decree Closing Certain Affiliate Cases; (III) Granting Related Relief [ECF No. 3956]. The Debtors in the remaining chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, if any, are Westinghouse (0933), Stone & Webster Services LLC (5448), WEC Carolina Energy Solutions, Inc. (8735), WEC Carolina Energy Solutions, LLC (2002), WECTEC Global Project Services Inc. (8572), WECTEC LLC (6222), WECTEC Staffing Services LLC (4135). The Debtors principal offices are located at 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066. 2 W Wind Down Co LLC ( Wind Down Co ) is the company established on the Effective Date (as defined in the Objection) for the benefit of holders of claims against Westinghouse certain of its affiliates (collectively, the Debtors ), responsible for administering the Debtors obligations pursuant to the Debtors confirmed chapter 11 plan.
The Objection requests that the Bankruptcy Court disallow expunge the claims listed on Exhibit 1 to the Proposed Order, which is attached as Exhibit A to the Objection, on the ground that such claims have been amended superseded during the above-captioned chapter 11 cases. Any claim that the Bankruptcy Court expunges disallows will be treated as if it had not been filed will not be entitled to any distribution on account thereof. If you do NOT oppose the disallowance expungement of your claim(s) as specified on Exhibit 1, then you do NOT need to file a written response to the Objection you do NOT need to appear at the hearing. If you filed the applicable proof of claim you DO oppose the disallowance, expungement, reduction or reclassification of your claim(s) listed on Exhibit 1 then you MUST file with the Court serve on the parties listed below a written response ( Response ) to the Objection that is received on or before 400 p.m. Eastern Time on January 15, 2019 (the Response Deadline ). Any Response must contain, at a minimum, the following (i) a caption setting forth the name of the Bankruptcy Court, the names of the debtors, the case number the title of the Objection to which the response is directed; (ii) the name of the claimant description of the basis for the amount of the claim; (iii) a concise statement setting forth the reasons why the claim should not be disallowed expunged, including, but not limited to, the specific factual legal bases which will be relied upon in opposing the Objection; (iv) all documentation or other evidence of the claim, to the extent not included with the proof of claim previously filed with the Bankruptcy Court, which will be relied upon in opposing the Objection; (v) the address(es) to which Wind Down Co must return any reply to a Response, if different from that presented in the proof of claim; (vi) the name, address, telephone number of the person (which may be the claimant or a legal representative) possessing ultimate authority to reconcile, settle, or otherwise resolve the claim on behalf of the claimant. Any Response to the Motion must be in writing, shall conform to the Federal Rules of Bankruptcy Procedure the Local Bankruptcy Rules, shall be filed with the Bankruptcy Court (a) by attorneys practicing in the Bankruptcy Court, including attorneys admitted pro hac vice, electronically in accordance with General Order M-399 (which can be found at www.nysb.uscourts.gov), (b) by all other parties in interest, on a CD-ROM, in text-searchable portable document format (PDF) (with a hard copy delivered directly to Chambers), in accordance with the customary practices of the Bankruptcy Court General Order M-399, to the extent applicable, served in accordance with General Order M-399 the Order Pursuant to 11 U.S.C. 105(a) Fed. R. Bankr. P. 1015(c) 9007 Implementing Certain Notice Case Management Procedures, dated April 4, 2017 [ECF No. 101], so as to be filed received no later than January 15, 2019 at 400 p.m. (Eastern Time). If you file a written Response to the Objection, you should plan to appear at the Hearing. Wind Down Co, however, reserves the right to continue the hearing on the Objection with respect to claim(s) for which a Response has been received. If Wind Down Co does continue 2
the hearing with respect to such claim(s), then the hearing will be held at a later date. If Wind Down Co does not continue the hearing with respect to such claim(s), then a hearing on the Objection will be conducted on the above date. If no Responses are timely filed served with respect to the Objection, Wind Down Co may, on or after the Response 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. Dated November 30, 2018 New York, New York /s/ Kyle J. Kimpler Alan W. Kornberg Kyle J. Kimpler Lauren Shumejda PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, New York 10019 Telephone +1 (212) 373-3000 Facsimile +1 (212) 757-3990 akornberg@paulweiss.com kkimpler@paulweiss.com lshumejda@paulweiss.com Counsel to W Wind Down Co LLC 3
HEARING DATE AND TIME January 22, 2019 at 1100 a.m. (Eastern Time) RESPONSE DEADLINE January 15, 2019 at 400 p.m. (Eastern Time) THIS OMNIBUS OBJECTION TO CLAIMS SEEKS TO DISALLOW AND EXPUNGE CERTAIN FILED PROOFS OF CLAIM. PLEASE CAREFULLY REVIEW THIS OBJECTION AND THE ATTACHMENTS HERETO TO DETERMINE WHETHER THE OBJECTION AFFECTS ANY CLAIM YOU MAY HAVE FILED. IF YOU HAVE QUESTIONS, PLEASE CONTACT NEAL PAUL DONNELLY AT (212) 373-3510 OR NDONNELLY@PAULWEISS.COM. PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, New York 10019 Telephone +1 (212) 373-3000 Facsimile +1 (212) 757-3990 Alan W. Kornberg Kyle J. Kimpler Lauren Shumejda Counsel to W Wind Down Co LLC UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------------------------- x In re Chapter 11 WESTINGHOUSE ELECTRIC COMPANY Case No. 17-10751 (MEW) LLC, et al., Debtors. 1 (Jointly Administered) -------------------------------------------------------- x TWENTY-FOURTH OMNIBUS OBJECTION TO CLAIMS ( ) 1 On September 25, 2018, many of the Debtors Chapter 11 Cases were closed pursuant to the Court s Order (I) Consolidating the Administration of Certain Remaining Matters at the Lead Case; (II) Entering a Final Decree Closing Certain Affiliate Cases; (III) Granting Related Relief [ECF No. 3956]. The Debtors in the remaining chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, if any, are Westinghouse (0933), Stone & Webster Services LLC (5448), WEC Carolina Energy Solutions, Inc. (8735), WEC Carolina Energy Solutions, LLC (2002), WECTEC Global Project Services Inc. (8572), WECTEC LLC (6222), WECTEC Staffing Services LLC (4135). The Debtors principal offices are located at 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
THE HONORABLE MICHAEL E. WILES, UNITED STATES BANKRUPTCY JUDGE W Wind Down Co LLC ( Wind Down Co ), the company established on the Effective Date (as defined herein) for the benefit of holders of claims against Westinghouse ( WEC ) certain of its affiliates (collectively, the Debtors ), responsible for administering the Debtors obligations pursuant to the Debtors confirmed chapter 11 plan, as directed by the Plan Oversight Board, respectfully represents Background 1. On March 29, 2017 (the Petition Date ), each Debtor commenced with this Court a voluntary case under chapter 11 of title 11 of the United States Code (the Bankruptcy Code ). The Debtors chapter 11 cases are being jointly administered for procedural purposes only pursuant to Rule 1015(b) of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ). 2. On November 15, 2017, the Court entered an order (the Omnibus Claim Objections Order ) authorizing the Debtors to file omnibus objections seeking reduction, reclassification /or disallowance of certain classes of claims [ECF No. 1761]. 3. On March 28, 2018, the Court entered an order [ECF No. 2988] (the Confirmation Order ) confirming the Debtors Modified Second Joint Chapter 11 Plan of Reorganization [ECF No. 2986] (the Plan ). The Plan became effective on August 1, 2018 (the Effective Date ). 2 2 Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to such terms in the Plan. 2
4. Wind Down Co was created on the Effective Date pursuant to the Plan to, among other things, analyze reconcile claims filed in these cases. Specifically, under sections 5.4(d) 8.1 of the Plan, Wind Down Co is vested with the authority to object to, seek to subordinate, estimate, compromise or settle any all claims against the Debtors, except to the extent claims have been previously allowed other than Assumed Liabilities, as directed by the Plan Oversight Board. 5. Additional information regarding the Debtors businesses, capital structure, events during these chapter 11 cases is set forth in the disclosure statement approved in connection with the Plan [ECF No. 2623]. Jurisdiction 6. This Court has jurisdiction to consider this matter pursuant to 28 U.S.C. 157 1334. This is a core proceeding pursuant to 28 U.S.C. 157(b). Venue is proper before this Court pursuant to 28 U.S.C. 1408 1409. Relief Requested 7. Wind Down Co files this objection pursuant to section 502(b) of the Bankruptcy Code Bankruptcy Rule 3007(d), seeking entry of an order, substantially in the form annexed hereto as Exhibit A (the Proposed Order ), disallowing expunging the claims listed on Exhibit 1 thereto (collectively, the ). 8. Wind Down Co has examined each Claim determined that each claim under the heading to be Disallowed Expunged is amended superseded by a subsequently filed claim identified on Exhibit 1 under the heading Remaining (collectively, the Remaining ). 3
9. In accordance with the Plan Confirmation Order, to ensure that the claims register does not inaccurately overstate the Debtors liabilities, to expedite recoveries to creditors by reducing the cash reserve funded for distributions to holders of claims that are neither allowed nor disallowed or disputed in these cases, reverting the amount of funds reserved for the to the Segregated Account for the benefit of allowed Class 3A General Unsecured, Wind Down Co seeks entry of the Proposed Order disallowing expunging the from the claims register. The supporting documentation filed with each disallowed expunged Claim will be deemed incorporated into the corresponding Remaining Claim indicated. 10. Wind Down Co requests that each Remaining Claim be deemed to have been filed on the date the original corresponding Claim was filed by a claimant. The Should Be Disallowed 11. A filed proof of claim is deemed allowed, unless a party in interest... objects. 11 U.S.C. 502(a). Section 502(b)(1) of the Bankruptcy Code provides, in relevant part, that a claim may not be allowed to the extent that such claim is unenforceable against the debtor property of the debtor, under any agreement or applicable law. 11 U.S.C. 502(b)(1). 12. Bankruptcy Rule 3007(d) permits a debtor to file objections to more than one claim on the basis that, among other things, such claims have been amended by subsequently filed proofs of claim. Fed. R. Bankr. P. 3007(d)(3). 13. Upon an objection, the claimant has the burden to demonstrate the validity of the claim. See Rozier v. Rescap Borrower Tr. (In re Residential Capital, LLC), 15 Civ. 3248, 2016 WL 796860, at *9 (S.D.N.Y. Feb. 22, 2016); In re Arcapita Bank B.S.C.(c), No. 12 4
11076(SHL), 2013 WL 6141616, at *1 (Bankr. S.D.N.Y. Nov. 21, 2013), aff d sub nom. In re Arcapita Bank B.S.C.(c), 508 B.R. 814 (S.D.N.Y. 2014); In re Motors Liquidation Co., No. 09-50026, 2012 WL 1886755, at *3 (S.D.N.Y. May 12, 2012); In re Oneida, Ltd., 400 B.R. 384, 389 (Bankr. S.D.N.Y. 2009), aff d, No. 09 Civ. 2229 (DC), 2010 WL 234827, at *5 (S.D.N.Y. Jan. 22, 2010). 14. that are amended superseded by subsequent claims filed by the same creditor are routinely disallowed expunged. See, e.g., Holzer v. Barnard, 2016 WL 4046767, at *5 (E.D.N.Y. July 27, 2016); In re Dewey & Leboeuf LLP, 2014 WL 201586, at *2 (Bankr. S.D.N.Y. Jan. 16, 2014) (finding that [C]laim number 833 states a claim by the same creditor for the same purported liability identified in the later-filed Stanwyck Claim... The Court therefore concludes that claim number 833 was amended superseded by the Stanwyck Claim, claim number 833 should therefore be disallowed expunged. ); In re Enron Corp., Case No. 01 B 16034(AJG), 2005 WL 3874285, at *1 n.1 (Bankr. S.D.N.Y. Oct. 5, 2005) (noting that [i]n as much as the Initial Claim was amended superseded by the Claim, it was disallowed expunged.... ). 15. Wind Down Co examined each Claim determined that each has been amended superseded by a subsequently-filed Remaining Claim. Accordingly, Wind Down Co seeks entry of an order disallowing expunging the. Reservation of Rights 16. Wind Down Co reserves all rights with respect to the Remaining. Wind Down Co reserves the right to object in the future to any of the proofs of claim listed in this Objection on any ground, to amend, modify, /or supplement this Objection 5
to the extent an objection to a claim is not granted. In addition, Wind Down Co reserves its right to later object to any Remaining Claim on the basis that the claims alleged in a Remaining Claim constitute new late-filed claims. Notice 17. Notice of this Objection has been provided in accordance with the Bankruptcy Rule 3007 the Order Pursuant to 11 U.S.C. 105(a) Fed. R. Bankr. P. 1015(c) 9007 Implementing Certain Notice Case Management Procedures, dated April 4, 2017 [ECF No. 101]. Wind Down Co submits that, in view of the facts circumstances, such notice is sufficient no other or further notice need be provided. 18. No previous request for the relief sought herein has been made to this or any other Court. 6
WHEREFORE, Wind Down Co respectfully requests entry of an order granting the relief requested herein such other further relief as is just. Dated November 30, 2018 New York, New York /s/ Kyle J. Kimpler Alan W. Kornberg Kyle J. Kimpler Lauren Shumejda PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, New York 10019 Telephone +1 (212) 373-3000 Facsimile +1 (212) 757-3990 akornberg@paulweiss.com kkimpler@paulweiss.com lshumejda@paulweiss.com Counsel to W Wind Down Co LLC 7
Exhibit A Proposed Order
UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------------------------- x In re Chapter 11 WESTINGHOUSE ELECTRIC COMPANY Case No. 17-10751 (MEW) LLC, et al., Debtors. 1 (Jointly Administered) -------------------------------------------------------- x ORDER GRANTING TWENTY-FOURTH OMNIBUS OBJECTION TO CLAIMS ( ) Upon the Twenty-Fourth Omnibus Objection to ( ) (ECF No. [ ]) (the Objection ), filed by W Wind Down Co LLC ( Wind Down Co ) pursuant to section 502(b) of title 11 of the United States Code (the Bankruptcy Code ) Rule 3007(d) of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ); the Court having jurisdiction to consider the Objection the relief requested therein in accordance with 28 U.S.C. 157 1334 the Sting Order of Reference M-431, dated January 31, 2012 (Preska, C.J.); consideration of the Objection the relief requested therein being a core proceeding pursuant to 28 U.S.C. 157(b); venue being proper before this Court pursuant to 28 U.S.C. 1408 1409; due proper notice of the Objection having been 1 On September 25, 2018, many of the Debtors Chapter 11 Cases were closed pursuant to the Court s Order (I) Consolidating the Administration of Certain Remaining Matters at the Lead Case; (II) Entering a Final Decree Closing Certain Affiliate Cases; (III) Granting Related Relief [ECF No. 3956]. The Debtors in the remaining chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, if any, are Westinghouse (0933), Stone & Webster Services LLC (5448), WEC Carolina Energy Solutions, Inc. (8735), WEC Carolina Energy Solutions, LLC (2002), WECTEC Global Project Services Inc. (8572), WECTEC LLC (6222), WECTEC Staffing Services LLC (4135). The Debtors principal offices are located at 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
provided in accordance with Bankruptcy Rule 3007 the Order Pursuant to 11 U.S.C. 105(a) Fed. R. Bankr. P. 1015(c) 9007 Implementing Certain Notice Case Management Procedures; a hearing having been held on January 22, 2019 at 1100 a.m. (Eastern Time) to consider the relief requested in the Objection (the Hearing ); movant s counsel having certified that no responses to the claims to be expunged pursuant to this order were filed or received; the Court having found determined that the relief sought in the Objection is in the best interests of the creditors all parties in interest, that the legal factual bases set forth in the Objection establish just cause for the relief granted herein; after due deliberation sufficient cause appearing therefor, it is ORDERED that the relief requested in the Objection is granted; it is further ORDERED that, pursuant to section 502(b) of the Bankruptcy Code Bankruptcy Rule 3007, each of the claims listed under the heading to be Disallowed Expunged on Exhibit 1 annexed hereto (collectively, the ) is hereby disallowed expunged; it is further ORDERED that each of the claims listed under the heading, Remaining on Exhibit 1 (collectively, the Remaining ), is deemed to have been filed on the date the original corresponding Claim was filed by a claimant, provided, however, that Wind Down Co s rights to later object to any Remaining Claim on the basis that the claims alleged in a Remaining Claim were not amendments to the original corresponding Claim, but constitute new /or late-filed claims, to later object to any Remaining Claim on any other basis, are hereby preserved; it is further 2
ORDERED that Wind Down Co, the claims noticing agent, the Clerk of this Court are authorized to take all actions necessary or appropriate to give effect to this Order; it is further ORDERED that this Court shall retain jurisdiction over the claimants whose claims are subject to the Objection with respect to any matters related to or arising from the Objection or the implementation of this Order. Dated, 2019 New York, New York HONORABLE MICHAEL E. WILES UNITED STATES BANKRUPTCY JUDGE 3
Exhibit 1
Twenty Fourth Omnibus Objection to ( ) Exhibit 1 Westinghouse, et al. Case No. 17-10751 (MEW), Jointly Administered CLAIMS TO BE DISALLOWED AND EXPUNGED REMAINING CLAIMS ABB Inc. Name Address of Claimant Claim # Debtor Robinson Cole LLP 280 Trumbull Street Hartford, CT 06492 Claim Amount 2901 WECTEC Global Project Services Inc. $4,543,785.06 Grounds For Objection Objection Page Reference ABB Inc. Hartford, CT 06103 Name Address of Claimant Claim # Debtor Jamie Connelly, Esq. c/o Robinson Cole LLP 280 Trumbull St 3686 WECTEC Global Project Services Inc. Claim Amount $2,666,374.82 $4,543,785.06 $2,666,374.82 Carolina Fabricators, Inc. Gleissner Law Firm, LLC 1237 Gadsden Street, Suite 200A Columbia, SC 29201-3098 2471 WEC Carolina Energy Solutions, Inc. $15,679.00 Carolina Fabricators, Inc. 1237 Gadsden Street, Suite 200A Columbia, SC 29201 3604 WEC Carolina Energy Solutions, Inc. $24,191.00 $15,679.00 $24,191.00 (1) In the "Claim Amount Priority" column, = secured claim, = administrative expense claim, = priority claim, = unsecured claim = total claim. The amounts listed are taken directly from the proofs of claim, thus replicate any mathematical errors on the proofs of claim. Where the claim amount is zero, unliquidated, unidentified, or otherwise cannot be determined, the amount listed is "0.00". (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. (3) Transfer Percentage refers to the percentage of the claim transferred from the original claimant to the current holder of the claim. Page 1
Twenty Fourth Omnibus Objection to ( ) Exhibit 1 Westinghouse, et al. Case No. 17-10751 (MEW), Jointly Administered CLAIMS TO BE DISALLOWED AND EXPUNGED REMAINING CLAIMS Name Address of Claimant Claim # Debtor Curtiss-Wright Flow Control Company Canada, Farris Enineering Division Whiteford, Taylor Preston LLC The Renaissance Centre, Suite 500 405 North King Street Wilmington, DE 19801 Claim Amount 3455 Westinghouse $131,479.00 Grounds For Objection Objection Page Reference Name Address of Claimant Claim # Debtor Curtiss-Wright Flow Control Company Canada, Farris Enineering Division 405 N. King Street, Suite 500 The Renaissance Centre Wilmington, DE 19801-3700 3677 Westinghouse Claim Amount $141,575.00 $131,479.00 $141,575.00 (1) In the "Claim Amount Priority" column, = secured claim, = administrative expense claim, = priority claim, = unsecured claim = total claim. The amounts listed are taken directly from the proofs of claim, thus replicate any mathematical errors on the proofs of claim. Where the claim amount is zero, unliquidated, unidentified, or otherwise cannot be determined, the amount listed is "0.00". (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. (3) Transfer Percentage refers to the percentage of the claim transferred from the original claimant to the current holder of the claim. Page 2
Twenty Fourth Omnibus Objection to ( ) Exhibit 1 Westinghouse, et al. Case No. 17-10751 (MEW), Jointly Administered CLAIMS TO BE DISALLOWED AND EXPUNGED REMAINING CLAIMS Name Address of Claimant Claim # Debtor Enertech, a Division of Curtiss-Wright Flow Control Corporation Whiteford, Taylor Preston LLC The Renaissance Centre 405 North King Street Wilmington, DE 19801 Claim Amount 3343 Westinghouse $95,108.00 Grounds For Objection Objection Page Reference Name Address of Claimant Claim # Debtor Enertech, a Division of Curtiss-Wright Flow Control Corporation 405 N. King Street, Suite 500 The Renaissance Wilmington, DE 19801-3700 3678 Westinghouse Claim Amount $204,557.00 $95,108.00 $204,557.00 Enertech, a Division of Curtiss-Wright Flow Control Corporation Whiteford, Taylor Preston LLC The Renaissance Centre, Suite 500 405 North King Street Wilmington, DE 19801 3428 Westinghouse $55,072.00 Enertech, a Division of Curtiss-Wright Flow Control Corporation 405 N. King Street, Suite 500 The Renaissance Wilmington, DE 19801-3700 3678 Westinghouse $204,557.00 $55,072.00 $204,557.00 EST Group, Inc. Whiteford, Taylor Preston LLC 405 N. King Street, Suite 500 Wilmington, DE 19801 3329 WECTEC Contractors Inc. $10,990.00 EST Group, Inc. 405 N. King Street, Suite 500 The Renaissance Centre Wilmington, DE 19801-3700 3679 WECTEC Contractors Inc. $27,214.00 $10,990.00 $27,214.00 (1) In the "Claim Amount Priority" column, = secured claim, = administrative expense claim, = priority claim, = unsecured claim = total claim. The amounts listed are taken directly from the proofs of claim, thus replicate any mathematical errors on the proofs of claim. Where the claim amount is zero, unliquidated, unidentified, or otherwise cannot be determined, the amount listed is "0.00". (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. (3) Transfer Percentage refers to the percentage of the claim transferred from the original claimant to the current holder of the claim. Page 3
Twenty Fourth Omnibus Objection to ( ) Exhibit 1 Westinghouse, et al. Case No. 17-10751 (MEW), Jointly Administered CLAIMS TO BE DISALLOWED AND EXPUNGED REMAINING CLAIMS Name Address of Claimant Claim # Debtor Flowserve Corporation Strasburger & Price LLP 901 Main Street, Suite 6000 Dallas, TX 75202 Claim Amount 3432 Westinghouse $3,689,789.10 Grounds For Objection Objection Page Reference Flowserve Corporation Dallas, TX 75202 Name Address of Claimant Claim # Debtor Strasburger & Price LLP 901 Main Street, Suite 6000 3664 Westinghouse Claim Amount $7,451,448.66 $3,689,789.10 $7,451,448.66 FRANKLIN NOVA GROUP INC 125 STILWELL COURT PITTSBURGH, PA 15228 1630 Westinghouse $8,000.00 Franklin Nova Group, Inc. Tucker Arensberg, PC 1500 One PPG Place Pittsburgh, PA 15222 3690 Westinghouse $8,360.00 $8,000.00 $8,360.00 General Cable Industries, Inc. 1 E. 4th St., Ste 1400 Cincinnati, OH 45202 1690 WECTEC Global Project Services Inc. $1,683,624.06 $1,364,780.70 General Cable Industries, Inc. Keating Muething Klekamp PLL 1 E. 4th St., Ste 1400 Cincinnati, OH 45202 3592 WECTEC Global Project Services Inc. $568,464.62 $3,048,404.76 $568,464.62 (1) In the "Claim Amount Priority" column, = secured claim, = administrative expense claim, = priority claim, = unsecured claim = total claim. The amounts listed are taken directly from the proofs of claim, thus replicate any mathematical errors on the proofs of claim. Where the claim amount is zero, unliquidated, unidentified, or otherwise cannot be determined, the amount listed is "0.00". (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. (3) Transfer Percentage refers to the percentage of the claim transferred from the original claimant to the current holder of the claim. Page 4
Twenty Fourth Omnibus Objection to ( ) Exhibit 1 Westinghouse, et al. Case No. 17-10751 (MEW), Jointly Administered CLAIMS TO BE DISALLOWED AND EXPUNGED REMAINING CLAIMS Name Address of Claimant Claim # Debtor General Supply & Services, Inc. d/b/a Gexpro Ruberto, Israel & Weiner, P.C. 225 State Street, 7th floor Boston, MA 02109 Claim Amount 3043 WECTEC LLC $308,733.22 Grounds For Objection Objection Page Reference Name Address of Claimant Claim # Debtor Rexel, USA, Inc. d/b/a Gexpro 3615 WECTEC LLC Ruberto, Israel & Weiner, P.C. 255 State Street, 7th Floor Boston, MA 02190 Claim Amount $1,860,659.82 $1,624,322.46 $2,169,393.04 $1,624,322.46 Nova Machine Products, Inc. Whiteford, Taylor Preston LLC 405 N. King Street, Suite 500 Wilmington, DE 19801 3321 WECTEC Global Project Services Inc. $12,969.63 Nova Machine Products, Inc. 405 N. King Street, Suite 500 The Renaissance Centre Wilmington, DE 19801-3700 3676 WECTEC Global Project Services Inc. $1,030,582.00 $12,969.63 $1,030,582.00 Nova Machine Products, Inc. Whiteford, Taylor Preston LLC The Renaissance Centre 405 North King Street Wilmington, DE 19801 3345 WECTEC Global Project Services Inc. $1,657,701.00 Nova Machine Products, Inc. 405 N. King Street, Suite 500 The Renaissance Centre Wilmington, DE 19801-3700 3676 WECTEC Global Project Services Inc. $1,030,582.00 $1,657,701.00 $1,030,582.00 (1) In the "Claim Amount Priority" column, = secured claim, = administrative expense claim, = priority claim, = unsecured claim = total claim. The amounts listed are taken directly from the proofs of claim, thus replicate any mathematical errors on the proofs of claim. Where the claim amount is zero, unliquidated, unidentified, or otherwise cannot be determined, the amount listed is "0.00". (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. (3) Transfer Percentage refers to the percentage of the claim transferred from the original claimant to the current holder of the claim. Page 5
Twenty Fourth Omnibus Objection to ( ) Exhibit 1 Westinghouse, et al. Case No. 17-10751 (MEW), Jointly Administered CLAIMS TO BE DISALLOWED AND EXPUNGED REMAINING CLAIMS Orpalis 52 Rue Marclan Muret, 31600 Name Address of Claimant Claim # Debtor Claim Transferred To CRG Financial LLC 100 Union Ave Cresskill, NJ 07626 Transfer Percentage = 100.00% Claim Amount 343 Westinghouse $5,990.06 $5,990.06 Grounds For Objection Objection Page Reference Cresskill, NJ 07626 Name Address of Claimant Claim # Debtor CRG Financial LLC (As Assignee of Orpalis) 100 Union Avenue 3655 Westinghouse Claim Amount $5,990.06 $5,990.06 Pennatronics Corporation 75 Technology Drive PO Box 638 California, PA 15419 313 Westinghouse $726,818.13 $172,065.72 Pennatronics Corporation 75 Technology Drive PO Box 638 California, PA 15419 3691 Westinghouse $16,864.50 $898,883.85 $16,864.50 (1) In the "Claim Amount Priority" column, = secured claim, = administrative expense claim, = priority claim, = unsecured claim = total claim. The amounts listed are taken directly from the proofs of claim, thus replicate any mathematical errors on the proofs of claim. Where the claim amount is zero, unliquidated, unidentified, or otherwise cannot be determined, the amount listed is "0.00". (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. (3) Transfer Percentage refers to the percentage of the claim transferred from the original claimant to the current holder of the claim. Page 6
Twenty Fourth Omnibus Objection to ( ) Exhibit 1 Westinghouse, et al. Case No. 17-10751 (MEW), Jointly Administered CLAIMS TO BE DISALLOWED AND EXPUNGED REMAINING CLAIMS Name Address of Claimant Claim # Debtor Qualtech, A Division of Curtiss-Wright Flow Control Service Corporation Whiteford, Taylor Preston LLC The Renaissance Centre, Suite 500 405 North King Street Wilmington, DE 19801 Claim Amount 3347 Westinghouse $476,593.00 Grounds For Objection Objection Page Reference Name Address of Claimant Claim # Debtor Qualtech, a Division of Curtiss-Wright Flow Control Service Cororation 405 N. King Street, Suite 500 The Renaissance Centre Wilmington, DE 19801-3700 3680 Westinghouse Claim Amount $476,593.00 Qualtech, A Division of Curtiss-Wright Flow Control Service Corporation Whiteford, Taylor Preston LLC The Renaissance Centre, Suite 500 405 North King Street Wilmington, DE 19801 3426 Westinghouse $764,622.00 Qualtech, a Division of Curtiss-Wright Flow Control Service Cororation 405 N. King Street, Suite 500 The Renaissance Centre Wilmington, DE 19801-3700 3680 Westinghouse $764,622.00 Russ Debnam PO Box 1116 Holly Springs, NC 27540 1698 WECTEC Global Project Services Inc. $3,095,820.00 Russ V. Debnam PO Box 1116 Holly Springs, NC 27540 3644 WECTEC Global Project Services Inc. $3,095,820.00 $3,095,820.00 $3,095,820.00 (1) In the "Claim Amount Priority" column, = secured claim, = administrative expense claim, = priority claim, = unsecured claim = total claim. The amounts listed are taken directly from the proofs of claim, thus replicate any mathematical errors on the proofs of claim. Where the claim amount is zero, unliquidated, unidentified, or otherwise cannot be determined, the amount listed is "0.00". (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. (3) Transfer Percentage refers to the percentage of the claim transferred from the original claimant to the current holder of the claim. Page 7
Twenty Fourth Omnibus Objection to ( ) Exhibit 1 Westinghouse, et al. Case No. 17-10751 (MEW), Jointly Administered CLAIMS TO BE DISALLOWED AND EXPUNGED REMAINING CLAIMS Name Address of Claimant Claim # Debtor US Department of Labor OSHA Boston Regional Solicitors Office, US Dept of Labo JFK Federal Building, Room E-375 15 Sudbury St Boston, MA 02203 Claim Transferred To David Proulx 1 Prescott Heights Road Hooksett, NH 03106 Transfer Percentage = 100.00% Claim Amount 2480 Westinghouse Grounds For Objection Objection Page Reference Boston, MA 02203 Name Address of Claimant Claim # Debtor US Department of Labor OSHA J.F.K. Federal Building, Room E-340 15 Sudbury Street 3645 Westinghouse Claim Amount $12,850.00 $2,150.00 $15,000.00 Utah Central Railway Company, LLC 10060 Skinner Lake Drive Jacksonville, FL 32246 Claim Transferred To CRG FINANCIAL LLC 100 UNION AVENUE 329 Westinghouse $17,110.08 $17,110.08 CRG Financial LLC (As Assignee of Utah Central Railway Co.) 100 Union Avenue Cresskill, NJ 07626 3661 Westinghouse $1,407.38 $15,702.70 $17,110.08 CRESSKILL, NJ 07626 Transfer Percentage = 100.00% WESTMORELAND COUNTY COMMUNITY 145 PAVILLION LN Youngwood, PA 15697-1814 Claim Transferred To CRG Financial LLC 100 Union Ave 1128 Westinghouse $30,000.00 $30,000.00 CRG Financial LLC (As Assignee of Westmorel County Community) 100 Union Avenue Cresskill, NJ 07626 3660 Westinghouse $8,187.50 $21,812.50 $30,000.00 Cresskill, NJ 07626 Transfer Percentage = 100.00% (1) In the "Claim Amount Priority" column, = secured claim, = administrative expense claim, = priority claim, = unsecured claim = total claim. The amounts listed are taken directly from the proofs of claim, thus replicate any mathematical errors on the proofs of claim. Where the claim amount is zero, unliquidated, unidentified, or otherwise cannot be determined, the amount listed is "0.00". (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. (3) Transfer Percentage refers to the percentage of the claim transferred from the original claimant to the current holder of the claim. Page 8