HEARING DATE AND TIME: October 2, 2018 at 11:00 a.m. (Eastern Time) Pg 1 of 32 RESPONSE DEADLINE: September 25, 2018 at 4:00 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(S) YOU MAY HAVE FILED. IF YOU HAVE QUESTIONS, PLEASE CONTACT OLGA PESHKO AT (212) 310-8042. UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------ x In re : Chapter 11 : WESTINGHOUSE ELECTRIC COMPANY : Case No. 17-10751 (MEW), et al., : : : Debtors. 1 : (Jointly Administered) : ------------------------------------------------------------ x NOTICE OF TWENTY-THIRD OMNIBUS OBJECTION TO CLAIMS (No Liability Claims) PLEASE TAKE NOTICE that on August 30, 2018, Wind Down Co 2 filed the annexed Twenty Third Omnibus Objection to Claims (No Liability Claims) (the Objection ), pursuant to sections 105(a) and 502(b) of title 11 of the United States Code (the Bankruptcy Code ) and 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 October 2, 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 (8538), Field Services, (2550), Nuclear Technology Solutions (1921), PaR Nuclear Holding Co., Inc. (7944), PaR Nuclear, Inc. (6586), PCI Energy Services (9100), Shaw Global Services, (0436), Shaw Nuclear Services, Inc. (6250), Stone & Webster Asia Inc. (1348), Stone & Webster Construction Inc. (1673), Stone & Webster International Inc. (1586), Stone & Webster Services (5448), Toshiba Nuclear Energy Holdings (UK) Limited (N/A), TSB Nuclear Energy Services Inc. (2348), WEC Carolina Energy Solutions, Inc. (8735), WEC Carolina Energy Solutions, (2002), WEC Engineering Services Inc. (6759), WEC Equipment & Machining Solutions, (3135), WEC Specialty (N/A), WEC Welding and Machining, (8771), WECTEC Contractors Inc. (4168), WECTEC Global Project Services Inc. (8572), WECTEC (6222), WECTEC Staffing Services (4135), Energy Systems (0328), Industry Products International Company (3909), International Technology (N/A), and Technology Licensing Company (5961). The Debtors principal offices are located at 1000 Drive, Cranberry Township, Pennsylvania 16066. 2 W Wind Down Co ( Wind Down Co ) is the company established on the Effective Date (as defined in the Objection) for the benefit of holders of claims against and certain of its affiliates (collectively, the Debtors ), and responsible for administering the Debtors obligations pursuant to the Debtors confirmed chapter 11 plan. WEIL:\96690671\4\80768.0017
Pg 2 of 32 2018 at 11:00 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 ). The Objection requests that the Bankruptcy Court disallow and expunge the claims listed on Exhibit 1 to the Proposed Order, which is attached as Exhibit A to the Objection, on the ground that Wind Down Co had no liability for such claims. Any claim that the Bankruptcy Court expunges and disallows will be treated as if it had not been filed and will not be entitled to any distribution on account thereof. If you do NOT oppose the disallowance and expungement of your claim(s) as specified on, then you do NOT need to file a written response to the Objection and you do NOT need to appear at the hearing. If you filed the applicable proof of claim and you DO oppose the disallowance, expungement, reduction or reclassification of your claim(s) listed on then you MUST file with the Court and serve on the parties listed below a written response ( Response ) to the Objection that is received on or before 4:00 p.m. Eastern Time on September 25, 2018 (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 and the title of the Objection to which the response is directed; (ii) the name of the claimant and 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 and expunged, including, but not limited to, the specific factual and 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; and (vi) the name, address, and 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 and the Local Bankruptcy Rules, and 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), and (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 and General Order M-399, to the extent applicable, and served in accordance with General Order M-399 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, dated April 4, 2017 [ECF No. 101], so as to be filed and received no later than September 25, 2018 at 4:00 p.m. (Eastern Time). WEIL:\96690671\4\80768.0017
Pg 3 of 32 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 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 and 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: August 30, 2018 New York, New York /s/ David N Griffiths Gary T. Holtzer Robert J. Lemons Garrett A. Fail David N. Griffiths WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, New York 10153 Telephone: (212) 310-8000 Facsimile: (212) 310-8007 Counsel to Wind Down Co WEIL:\96690671\4\80768.0017
HEARING DATE AND TIME: October 2, 2018 at 11:00 a.m. (Eastern Time) Pg 4 of 32 RESPONSE DEADLINE: September 25, 2018 at 4:00 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(S) YOU MAY HAVE FILED. IF YOU HAVE QUESTIONS, PLEASE CONTACT OLGA PESHKO AT (212) 310-8042. WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, New York 10153 Telephone: (212) 310-8000 Facsimile: (212) 310-8007 Gary T. Holtzer Robert J. Lemons Garrett A. Fail David N. Griffiths Counsel to Wind Down Co UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------ x In re : Chapter 11 : WESTINGHOUSE ELECTRIC COMPANY : Case No. 17-10751 (MEW), et al., : : : Debtors. 1 : (Jointly Administered) : ------------------------------------------------------------ x TWENTY-THIRD OMNIBUS OBJECTION TO CLAIMS (No Liability Claims) 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 (8538), Field Services, (2550), Nuclear Technology Solutions (1921), PaR Nuclear Holding Co., Inc. (7944), PaR Nuclear, Inc. (6586), PCI Energy Services (9100), Shaw Global Services, (0436), Shaw Nuclear Services, Inc. (6250), Stone & Webster Asia Inc. (1348), Stone & Webster Construction Inc. (1673), Stone & Webster International Inc. (1586), Stone & Webster Services (5448), Toshiba Nuclear Energy Holdings (UK) Limited (N/A), TSB Nuclear Energy Services Inc. (2348), WEC Carolina Energy Solutions, Inc. (8735), WEC Carolina Energy Solutions, (2002), WEC Engineering Services Inc. (6759), WEC Equipment & Machining Solutions, (3135), WEC Specialty (N/A), WEC Welding and Machining, (8771), WECTEC Contractors Inc. (4168), WECTEC Global Project Services Inc. (8572), WECTEC (6222), WECTEC Staffing Services (4135), Energy Systems (0328), Industry Products International Company (3909), International Technology (N/A), and Technology Licensing Company (5961). The Debtors principal offices are located at 1000 Drive, Cranberry Township, Pennsylvania 16066. WEIL:\96690671\4\80768.0017
Pg 5 of 32 THE HONORABLE MICHAEL E. WILES, UNITED STATES BANKRUPTCY JUDGE: W Wind Down Co ( Wind Down Co ), the company established on the Effective Date (as defined herein) for the benefit of holders of claims against ( WEC ) and certain of its affiliates (collectively, the Debtors ), and 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 were authorized to continue to operate their businesses and manage their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in these chapter 11 cases. 2. 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 ). 3. On April 7, 2017, the United States Trustee for Region 2 (the U.S. Trustee ) appointed the Statutory Unsecured Claimholders Committee (the UCC ) pursuant to section 1102 of the Bankruptcy Code. On October 2, 2017, and December 19, 2017, the U.S. Trustee filed amended notices of appointment [ECF Nos. 1431 and 1954] removing members from the UCC. WEIL:\96690671\4\80768.0017
Pg 6 of 32 4. On November 15, 2017 the Court entered an order (the Omnibus Claim Objections Order ) authorizing the Debtors to file omnibus objections seeking reduction, reclassification and/or disallowance of certain classes of claims [ECF No. 1761]. 5. On March 28, 2018 the Court entered an order [ECF No. 2988] (the Confirmation Order ) confirming the Debtors Modified Second Amended Joint Chapter 11 Plan of Reorganization [ECF No. 2986] (the Plan ). The Plan became effective on August 1, 2018 (the Effective Date ). 2 6. Pursuant to sections 5.4(d) and 8.1 of the Plan, Wind Down Co is vested with the authority to object to, seek to subordinate, estimate, compromise or settle any and all claims against the Debtors, except to the extend claims have been previously allowed and other than Assumed Liabilities, as directed by the Plan Oversight Board. 7. Additional information regarding the Debtors businesses, capital structure, and the circumstances leading to the commencement of these chapter 11 cases is set forth in the disclosure statement approved in connection with the Plan [ECF No. 2623]. Jurisdiction 8. This Court has jurisdiction to consider this matter pursuant to 28 U.S.C. 157 and 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 and 1409. Relief Requested 9. Wind Down Co files this Objection pursuant to section 502(b) of the Bankruptcy Code and Rule 3007(d) of the Federal Rules of Bankruptcy Procedure 2 Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to such terms in the Plan. WEIL:\96690671\4\80768.0017
Pg 7 of 32 (the Bankruptcy Rules ), seeking entry of an order substantially in the form annexed hereto as Exhibit A (the Proposed Order ), disallowing and expunging the claims listed on Exhibit 1 thereto (collectively, the No Liability Claims ). 10. Wind Down Co examined each No Liability Claim and determined that each claim under the heading Claims to be Disallowed and Expunged asserts a claim against the Debtors for which the Debtors and Wind Down Co have no liability. 11. In accordance with the Plan and Confirmation Order, to ensure that the claims register is accurate and does not inaccurately overstate the Debtors liabilities, and 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, and reverting the amount of funds reserved for the No Liability Claims to the Segregated Account for the benefit of allowed Class 3A General Unsecured Claims, Wind Down Co seeks entry of the Proposed Order disallowing and expunging the No Liability Claims from the claims register. The No Liability Claims Should Be Disallowed 12. 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 and property of the debtor, under any agreement or applicable law. 11 U.S.C. 502(b)(1). 13. Upon an objection, the claimant has the burden to demonstrate the validity of the claim. See Rozier v. Rescap Borrower Claims Tr. (In re Residential Capital, ), 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 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- WEIL:\96690671\4\80768.0017
Pg 8 of 32 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. Each of the No Liability Claims asserts a claim for potential rejection damages on account of contracts (the Contracts ) with one or more of the Debtors. However, in accordance with paragraph 25 of the Confirmation Order, on the Effective Date the Debtors assumed each of the Contracts by listing them on the Debtors Revised Schedule of Assumed Contracts and Schedule of Assigned Contracts [ECF No. 3624]. Furthermore, in accordance with the Plan and Confirmation Order, Wind Down Co paid and satisfied all prepetition cures under the Contracts. 15. There can be no rejection damages owing under assumed contracts. Therefore, Wind Down Co has no liability for any part of the No Liability Claims and requests that the Court disallow and expunge them in their entirety. Reservation of Rights 16. 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, and to amend, modify, and/or supplement this Objection to the extent an objection to a claim is not granted. Notice 17. Notice of this Objection has been provided in accordance with the 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, dated April 4, 2017 [ECF No. 101]. Wind Down Co submits that, in view of the facts and circumstances, such notice is sufficient and no other or further notice need be provided. WEIL:\96690671\4\80768.0017
Pg 9 of 32 18. No previous request for the relief sought herein has been made to this or any other Court. WHEREFORE, Wind Down Co respectfully requests entry of an order granting the relief requested herein and such other and further relief as is just. Dated: August 30, 2018 New York, New York /s/ David N. Griffiths Gary T. Holtzer Robert J. Lemons Garrett A. Fail David N. Griffiths WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, New York 10153 Telephone: (212) 310-8000 Facsimile: (212) 310-8007 Counsel to Wind Down Co WEIL:\96690671\4\80768.0017
Pg 10 of 32 Exhibit A Proposed Order WEIL:\96690671\4\80768.0017
Pg 11 of 32 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------ x In re : Chapter 11 : WESTINGHOUSE ELECTRIC COMPANY : Case No. 17-10751 (MEW), et al., : : : Debtors. 1 : (Jointly Administered) : ------------------------------------------------------------ x ORDER GRANTING TWENTY-THIRD OMNIBUS OBJECTION TO CLAIMS (No Liability Claims) Upon the Twenty Third Omnibus Objection to Claims (No Liability Claims) (ECF No. [ ]) (the Objection ), filed by W Wind Down Co ( Wind Down Co ) pursuant to section 502(b) of title 11 of the United States Code (the Bankruptcy Code ) and Rule 3007(d) of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ); and the Court having jurisdiction to consider the Objection and the relief requested therein in accordance with 28 U.S.C. 157 and 1334 and the Amended Standing Order of Reference M-431, dated January 31, 2012 (Preska, C.J.); and consideration of the Objection and the relief requested therein being a core 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 (8538), Field Services, (2550), Nuclear Technology Solutions (1921), PaR Nuclear Holding Co., Inc. (7944), PaR Nuclear, Inc. (6586), PCI Energy Services (9100), Shaw Global Services, (0436), Shaw Nuclear Services, Inc. (6250), Stone & Webster Asia Inc. (1348), Stone & Webster Construction Inc. (1673), Stone & Webster International Inc. (1586), Stone & Webster Services (5448), Toshiba Nuclear Energy Holdings (UK) Limited (N/A), TSB Nuclear Energy Services Inc. (2348), WEC Carolina Energy Solutions, Inc. (8735), WEC Carolina Energy Solutions, (2002), WEC Engineering Services Inc. (6759), WEC Equipment & Machining Solutions, (3135), WEC Specialty (N/A), WEC Welding and Machining, (8771), WECTEC Contractors Inc. (4168), WECTEC Global Project Services Inc. (8572), WECTEC (6222), WECTEC Staffing Services (4135), Energy Systems (0328), Industry Products International Company (3909), International Technology (N/A), and Technology Licensing Company (5961). The Debtors principal offices are located at 1000 Drive, Cranberry Township, Pennsylvania 16066. WEIL:\96690671\4\80768.0017
Pg 12 of 32 proceeding pursuant to 28 U.S.C. 157(b); and venue being proper before this Court pursuant to 28 U.S.C. 1408 and 1409; and due and proper notice of the Objection having been provided 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 a hearing having been held on October 2, 2018 at 11:00 a.m. (Eastern Time) to consider the relief requested in the Objection (the Hearing ); and movant s counsel having certified that no responses to the claims to be expunged pursuant to this order were filed or received; and the Court having found and determined that the relief sought in the Objection is in the best interests of the creditors and all parties in interest, and that the legal and factual bases set forth in the Objection establish just cause for the relief granted herein; and after due deliberation and sufficient cause appearing therefor, it is ORDERED that the relief requested in the Objection is granted; and it is further ORDERED that, pursuant to section 502(b) of the Bankruptcy Code and Bankruptcy Rule 3007, each of the claims listed under the heading Claims to be Disallowed and Expunged on Exhibit 1 annexed hereto (collectively, the No Liability Claims ) is hereby disallowed and expunged; and it is further ORDERED that Wind Down Co, the claims and noticing agent, and the Clerk of this Court are authorized to take all actions necessary or appropriate to give effect to this Order; and it is further 2 WEIL:\96690671\4\80768.0017
Pg 13 of 32 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:, 2018 New York, New York HONORABLE MICHAEL E. WILES UNITED STATES BANKRUPTCY JUDGE 3 WEIL:\96690671\4\80768.0017
Pg 14 of 32 No Liability Claims WEIL:\96690671\4\80768.0017
Pg 15 of 32, et al. 1966 Filed On: 8/29/2017 A. P. Services c/o Stephen B. Gerald, Whiteford Taylor Preston 405 N. King Street, Suite 500 Wilmington, DE 19801 2620 $0.00 $0.00 $0.00 $9,000,000.00 $9,000,000.00 Filed On: 8/31/2017 Arizona Public Service Company Matthew Derstine Snell Wilmer LLP 400 East Van Buren Street, Suite 1900 Phoenix, AZ 85004-2202 2420 Filed On: 8/31/2017 Calvert Cliffs Nuclear Power Plant, Attn Mark J. Packel, Esq. Assistant General Counsel, exelon Corporation Exelon Generation Company, 2301 Market Street, 22nd Floor Philadelphia, PA 19103 Page 1
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Pg 17 of 32, et al. 3042 PaR Nuclear, Inc. China Nuclear Energy Industry Corporation Dania Slim Pillsbury Winthrop Shaw Pittman LLP 324 Royal Palm Way, Suite 220 Palm Beach, FL 33480 2384 Filed On: 8/30/2017 China Nuclear Power Engineering Co., Ltd. Dania Slim Pillsbury Winthrop Shaw Pittman LLP 324 Royal Palm Way, Suite 220 Palm Beach, FL 33480 2386 Filed On: 8/30/2017 CNNP CHD Hebei Nuclear Power Co., Ltd Dania Slim Pillsbury Winthrop Shaw Pittman LLP 324 Royal Palm Way, Suite 220 Palm Beach, FL 33480 Page 3
Pg 18 of 32, et al. 2383 Filed On: 8/30/2017 CNNP Liaoning Nuclear Power Co., Ltd Dania Slim Plillsbury Winthrop Shaw Pittman LLP 324 Royal Palm Way, Suite 220 Palm Beach, FL 33480 2874 Comanche Peak Power Company, Greenberg Traurig, LLP, Attn Iskender H.Catto MetLife Building, 200 Park Avenue New York, NY 10166 2807 Continuum Dynamics Inc. Lisa S. Bonsall, Esq. McCarter and English, LLP 100 Mulberry Street Four Gateway Center Newark, NJ 07102 Page 4
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Pg 20 of 32, et al. 3059 PaR Nuclear, Inc. Dominion Energy Nuclear Connecticut, Inc. Aaron G. McCollough McGuireWoods LLP 77 W. Wacker Dr. Ste. 4100 Chicago, IL 60601 3046 Dominion Energy Services, Inc. Aaron G. McCollough 77 W. Wacker Dr. Ste 4100 Chicago, IL 60611 3004 Dominion Energy, Inc. Aaron G. McCollough McGuireWoods LLP 77 W. Wacker Dr. Ste. 4100 Chicago, IL 60601 3032 Dominion Generation, Inc. Aaron G. McCollough 77 W. Wacker Dr. Ste. 4100 Chicago, IL 60611 Page 6
Pg 21 of 32, et al. 2411 Filed On: 8/31/2017 Exelon Generation Company, Attn Mark J. Packel, Esquire Assistant General Counsel, Exelon Corporation 2301 Market Street, 22nd Floor Philadelphia, PA 19103 2373 FirstEnergy Nuclear Operating Company Filed On: 8/30/2017 Attn Rick C. Giannantonio, Esq. 341 White Pond Drive, Building B3 Akron, OH 44320 2777 Florida Power and Light Company Rachel Budke, Esq. 700 Universe Blvd Law Department Juno Beach, FL 33408 Page 7
Pg 22 of 32, et al. 2804 Louisiana Energy Services, Attn Noel Harris URENCO Limited URENCO Court, Sefton Park Bells Hill, Stoke Poges, Bucks SL2 4JS 2495 Technology Licensing Company Mitsubishi Heavy Industries, Ltd. Filed On: 8/31/2017 Takahiko Yoshida 16-5 Konan 2-Chome Minato-ku Shinagawa Tokyo, 108-8215 2496 Filed On: 8/31/2017 Mitsubishi Heavy Industries, Ltd. Takahiko Yoshida Manager, Legal Group 1 Legal & General Affairs Department 16-5, Konan 2-Chome, Minato-ku Tokyo, 102-8215 Page 8
Pg 23 of 32, et al. 2515 Filed On: 8/31/2017 International Technology Mitsubishi Heavy Industries, Ltd. Takahiko Yoshida Manager, Legal Group 1 Legal & General Affairs Department 16-5, Konan 2-Chome, Minato-ku Tokyo, 102-8215 2417 Filed On: 8/31/2017 Nine Mile Point Nuclear Station, Attn Mark J. Packel, Esq. Assistant General Counsel, Exelon Corporation Exelon Generation Company, 2301 Market Street, 22nd Floor Philadelphia, PA 19103 2836 Northern States Power Company Attn Kyle Hardwick c/o Faegre Baker Daniels LLP 90 South 7th Street, Suite 2200 Minneapolis, MN 55402 Page 9
Pg 24 of 32, et al. 2867 Northern States Power Company Attn Kyle Hardwick c/o Faegre Baker Daniels LLP 90 South 7th Street, Suite 2200 Minneapolis, MN 55402 2385 Filed On: 8/30/2017 Nuclear Power Institute of China Dania Slim Pillsbury Winthrop Shaw Pittman LLP 324 Royal Palm Way, Suite220 Palm Beach, FL 33480 3008 PaR Nuclear, Inc. Nuclear Power Qinshan Joint Venture Company Limited Dania Slim - Pilsbury Wintrop Shaw Pittman LLP 324 Royal Palm Way, Suite 220 Palm Beach, FL 33480 Page 10
Pg 25 of 32, et al. 2666 $0.00 $0.00 $0.00 $5,349,900.00 $5,349,900.00 Filed On: 8/31/2017 PSEG Nuclear Suzanne M Klar, Esq 80 Park Plaza T8D Newark, NJ 07102 3038 Toshiba Nuclear $0.00 $0.00 $0.00 $5,349,900.00 $5,349,900.00 Energy Holdings (UK) Limited PSEG Nuclear Suzanne M Klar, Esq PSEG Services Corp 80 Park Plaza T5D Newark, NJ 07102 2419 Filed On: 8/31/2017 R.E. Ginna Nuclear Power Plant, Attn Mark J. Packel, Esq. Exelon Generation Company, 2301 Market Street, 22nd Floor Philadelphia, PA 19103 Page 11
Pg 26 of 32, et al. 3027 Rosemount Nuclear Instruments, Inc. John J. Cruciani Husch Blackwell LLP 4801 Main Street, Suite 1000 Kansas City, MO 64112 3091 $550,378.55 $0.00 $0.00 $0.00 $550,378.55 Industry Products International Company Sanmen Nuclear Power Company Ltd. Lanying Huang and Jing Liu Sanmen County Zhejiang Province, 317112 3134 Sanmen Nuclear Power Company Ltd. Lanying Huang and Jing Liu Sanmen Nuclear Power Company Sanmen County, Zhejiang 317112 Page 12
Pg 27 of 32, et al. 3137 State Nuclear Power Automation System Engineering Company Jianguo Ye and Yongzhen Cao No. 428 East Jiangchuan Road Minhang District Minghang, Shanghai 200241 2769 State Nuclear Power Engineering Company Ai Xue Building 2, No. 888 Tianlin Road Minhang District Shanghai, Shanghai 200233 2770 Industry Products International Company State Nuclear Power Engineering Company Ai Xue Building 2, No. 888 Tianlin Road Minhang District Shanghai, Shanghai 200233 Page 13
Pg 28 of 32, et al. 2776 PaR Nuclear, Inc. State Nuclear Power Engineering Company Ai Xue Building 2, No. 888 Tianlin Road Minhang District Shanghai, Shanghai 200233 2075 Technology Licensing Company State Nuclear Power Technology Corporation Ltd. Filed On: 8/30/2017 Li Su Building 1, Compound No. 29 North Third Ring Road, Xicheng District Beijing, 100029 2100 Filed On: 8/30/2017 Stone & Webster International Inc. State Nuclear Power Technology Corporation Ltd. Li Su Building 1, Compound No. 29 North Third Ring Road, Xicheng District Beijing, 100029 Page 14
Pg 29 of 32, et al. 2112 Filed On: 8/30/2017 WECTEC Global Project Services Inc. State Nuclear Power Technology Corporation Ltd. Li Su Building 1, Compound No. 29 North Third Ring Road, Xicheng District Beijing, 100029 2114 Filed On: 8/30/2017 State Nuclear Power Technology Corporation Ltd. Li Su Building 1, Compound No. 29 North Third Ring Road, Xicheng District Beijing, 100029 2530 STP Nuclear Operating Company Filed On: 8/31/2017 Attn Kimberly A. Harshaw General Counsel PO Box 289 Wadsworth, TX 77483 Page 15
Pg 30 of 32, et al. 2779 $0.00 $0.00 $0.00 $675,952.65 $675,952.65 Sumitomo Corporation Sumitomo Corporation Of Americas 300 Madison Avenue New York, NY 10017 1929 Synopsys, Inc. Filed On: 8/28/2017 Mark A. Fink c/o Montgomery, McCracken, Walker and Rhoads, LLP 437 Madison Avenue New York, NY 10022 2615 Uranium Participation Bermuda Limited Filed On: 8/31/2017 Mac McDonald 1100-40 University Avenue Toronto, ON M5J 1T1 Page 16
Pg 31 of 32, et al. 2897 URENCO Deutschland GmbH URENCO Limited Attn Noel Harris URENCO Court, Sefton Park Bells Hill, Stoke Poges, Bucks SL2 4JS 2856 URENCO Enrichment Company, Ltd. Attn Noel Harris URENCO Limited URENCO Court, Sefton Park Bells Hill, Stoke Poges, Bucks SL2 4JS 2881 URENCO Nederland B.V. Attn Noel Harris URENCO Limited URENCO Court, Sefton Park Bells Hill, Stoke Poges, Bucks SL2 4JS Page 17
Pg 32 of 32, et al. 2892 URENCO UK LTD. URENCO LIMITED, ATTN NOEL HARRIS URENCO COURT, SEFTON PARK BELLS HILLS STOKE POGES, BUCKS SL24JS 3053 PCI Energy Services Virginia Electric and Power Company Aaron G. McCollough 77 W. Wacker Dr. Ste. 4100 Chicago, IL 60611 3055 Virginia Electric and Power Company Aaron G. McCollough 77 W. Wacker Dr. Ste. 4100 Chicago, IL 60611 Page 18