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Full title: Certification of Counsel Regarding Wind-Down Administrator's Fourth (4th) Omnibus Objection (Non-Substantive) Objection to Claims (related document(s)1507) Filed by Wind-Down Administrator. (Attachments: # 1 Exhibit A) (Feldman, Betsy) (Entered: 05/12/2021)

Document posted on May 11, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

In re: Case No. 20-10010 (CSS) BDC Inc., et al., (Jointly Administered) Debtors.1 Ref.(“Lasting”), Euler Hermes Agent for Athens Paper Co. (“Euler”), and Laurel Machine and Foundry (“Laurel”)In an effort to consensually resolve the 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are: BDC Inc. (1509); BDC Holdings, LLC (8504); ND, LLC (9109); BDC of Alabama, LLC (5598); BDC of Cincinnati, LLC (1334); BTC of Cincinnati, LLC (3462); BDC of Florida, LLC (5168); BDC of Kentucky, LLC (7392); BDC of Louisiana, LLC (4109); BDC of Madisonville, LLC (7310); BDC of Ohio, LLC (2720); BTC of Ohio, LLC (7837); BDC of South Carolina, LLC (0963); BDC of Texas, LLC (5060); CAS, LLC (9109); GSSD, LLC (9109); NDHT, LLC (7480); and BDC of Madisonville Sub, LLC (0314).Responses, the Wind-Down Administrator has agreed to withdraw the Objection without prejudice as it relates to the Disputed Claims of AutomationEdge, Lasting, and Laurel.The Revised Proposed Order does not seek any relief with respect to the Disputed Claims that are the subject of the Responses filed by AutomationEdge, Lasting, and Laurel.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE Chapter 11 In re: Case No. 20-10010 (CSS) BDC Inc., et al., (Jointly Administered) Debtors.1 Ref. Docket No. 1507 CERTIFICATION OF COUNSEL REGARDING WIND-DOWN ADMINISTRATOR’S FOURTH OMNIBUS OBJECTION TO CLAIMS (NON-SUBSTANTIVE) On April 27, 2021, the Wind-Down Administrator in the above-captioned cases filed the Wind-Down Administrator’s Fourth (4th) Omnibus (Non-Substantive) Objection to Claims Pursuant to Section 502 of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1 [Docket No. 1507] (the “Objection”).2 A proposed form of order was attached to the Objection as Exhibit 2 (the “Proposed Order”). The deadline to respond to the Objection was May 11, 2021 at 4:00 p.m. (ET) (the “Response Deadline”). Prior to the Response Deadline, the Wind-Down Administrator received responses (collectively, the “Responses”) from AutomationEdge Technologies, Inc. (“AutomationEdge”) [Docket No. 1512], Lasting Impressions Printing Inc. dba Farrell Svcs Inc. (“Lasting”), Euler Hermes Agent for Athens Paper Co. (“Euler”), and Laurel Machine and Foundry (“Laurel”) [Docket No. 1511] (collectively, the “Respondents”). In an effort to consensually resolve the 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are: BDC Inc. (1509); BDC Holdings, LLC (8504); ND, LLC (9109); BDC of Alabama, LLC (5598); BDC of Cincinnati, LLC (1334); BTC of Cincinnati, LLC (3462); BDC of Florida, LLC (5168); BDC of Kentucky, LLC (7392); BDC of Louisiana, LLC (4109); BDC of Madisonville, LLC (7310); BDC of Ohio, LLC (2720); BTC of Ohio, LLC (7837); BDC of South Carolina, LLC (0963); BDC of Texas, LLC (5060); CAS, LLC (9109); GSSD, LLC (9109); NDHT, LLC (7480); and BDC of Madisonville Sub, LLC (0314). The location of the Debtors’ service address is: The Wind-Down Administrator of the Debtors, 700 Canal Street, Suite 12E, Stamford, CT 06902, Attn: David Dunn. 2 All capitalized terms used and not otherwise defined herein have the meanings ascribed to them in the Objection.

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Responses, the Wind-Down Administrator has agreed to withdraw the Objection without prejudice as it relates to the Disputed Claims of AutomationEdge, Lasting, and Laurel. The Wind-Down Administrator has resolved the informal response of Euler through revisions to the proposed form of order for the Wind-Down Administrator’s Third (3rd) Omnibus (Non-Substantive) Objection to Claims Pursuant to Section 502 of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1 [Docket No. 1506]. A revised Proposed Order (the “Revised Proposed Order”) is attached hereto as Exhibit A.3 The Wind-Down Administrator submits that the Revised Proposed Order is appropriate and consistent with the Objection and their discussions with the Respondents, and that entry of the Revised Proposed Order is in the best interests of the Wind-Down Administrator, the estates, and the creditors. The Revised Proposed Order does not seek any relief with respect to the Disputed Claims that are the subject of the Responses filed by AutomationEdge, Lasting, and Laurel. 3 The only revisions to the Proposed Order were to remove from the exhibits thereto the Disputed Claims that are the subject of the Responses received for the reasons described herein. Accordingly, no blackline of the Revised Proposed Order is attached.

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WHEREFORE, the Wind-Down Administrator respectfully requests that the Court enter the Revised Proposed Order at the earliest convenience of the Court without further notice or hearing. Dated: May 12, 2021 YOUNG CONAWAY STARGATT & TAYLOR, LLP Wilmington, Delaware /s/ Betsy L. Feldman M. Blake Cleary (No. 3614) Kenneth J. Enos (No. 4544) Betsy L. Feldman (No. 6410) Rodney Square 1000 North King Street Wilmington, Delaware 19801 Telephone: (302) 571-6600 Facsimile: (302) 571-1256 mbcleary@ycst.com kenos@ycst.com bfeldman@ycst.com Counsel to the Wind-Down Administrator

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