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Full title: Reply in Further Support of Motion to Compel Production of Documents (RE: related document(s)1968 Motion (Other) filed by Interested Party Sander Esserman, 2017 Response filed by Debtor Bestwall LLC) filed by Felton Parrish on behalf of Sander Esserman, The Official Committee of Asbestos Claimants of Bestwall, LLC. (Attachments: # 1 Exhibit 1 # 2 Exhibit 2) (Parrish, Felton) (Entered: 08/26/2021)

Document posted on Aug 25, 2021 in the bankruptcy, 14 pages and 0 tables.

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THE OFFICIAL COMMITTEE OF ASBESTOS CLAIMANTS’ AND THE FUTURE CLAIMANTS’ REPRESENTATIVE’S REPLY IN FURTHER SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS Sander L. Esserman, in his capacity as the Future Claimants’ Representative (the “FCR”), together with the Official Committee of Asbestos Claimants (the “ACC” and collectively with the FCR, the “Claimants’ Representatives”) hereby submit this reply (the “Reply”) in further support of their Motion2 to compel Bestwall LLC (the “Debtor”) to produce documents responsive to the Official Committee of Asbestos Claimants’ and the Future Claimants’ Representative’s First Set of Document Requests to the Debtor, dated April 15, 2021 (the “Requests”). The Debtor’s artfully worded “commitments” and track record provide no assurance that the Debtor intends to produce certain requested information at all—or produce all of the information, including the privilege logs describing the information the Debtor withholds—on a schedule that affords the Claimants’ Representatives adequate time to analyze the information available only through discovery.Even if the Claimants’ Representatives could rely upon the Debtor’s caveated commitments to production, the Debtor has not committed to a date certain by which the Claimants’ Representatives will have in their possession all documents responsive to the Requests, including complete privilege logs identifying all documents responsive to the Requests but not produced. Even accepting that the August 10 communication as more of a “commitment” than it was, the Debtor still carved out privilege logs from its unilaterally selected, September 30, date.(“As the Court has stated numerous times, boilerplate objections to discovery requests are highly disfavored in this district and throughout the Fourth Circuit, and the failure to state objections with specificity may be regarded as a waiver of those objections.”); Mr. Dees’ Inc. v. Inmar, Inc, 1:10CV141, 2020 WL 6488700, at * 7 (M.D.N.C. Nov. 4, 2020) (“Defendants ‘fail[ed] to present valid objections to the [ACPTD R]equest [and thereby] “waived any legitimate objection [they] may have had[.]”’’).

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UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION In re Chapter 11 BESTWALL LLC1 Case No. 17-31795 (LTB) Debtor. THE OFFICIAL COMMITTEE OF ASBESTOS CLAIMANTS’ AND THE FUTURE CLAIMANTS’ REPRESENTATIVE’S REPLY IN FURTHER SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS Sander L. Esserman, in his capacity as the Future Claimants’ Representative (the “FCR”), together with the Official Committee of Asbestos Claimants (the “ACC” and collectively with the FCR, the “Claimants’ Representatives”) hereby submit this reply (the “Reply”) in further support of their Motion2 to compel Bestwall LLC (the “Debtor”) to produce documents responsive to the Official Committee of Asbestos Claimants’ and the Future Claimants’ Representative’s First Set of Document Requests to the Debtor, dated April 15, 2021 (the “Requests”). In further support of the Motion, the Claimants’ Representatives state as follows: PRELIMINARY STATEMENT 1. In its Objection3 to the Motion, the Debtor once again attempts to use its assurances of transparency and effort to detract from the present reality that must be addressed. The present reality is that, despite the Debtor’s claims of transparency and effort, the Claimants’ Representatives have received only a fraction of the information requested more than four 1 The last four digits of the Debtor’s taxpayer identification number are 5815. The Debtor’s address is 133 Peachtree Street, N.W., Atlanta, GA 30303. 2 Motion to Compel Production of Documents [Dkt. 1968] (the “Motion”). 3 Debtor’s Objection to Motion to Compel Production of Documents [Dkt. 2017] (the “Objection”). 8524395.2

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months ago and lack critical discovery from the Debtor. The Debtor’s artfully worded “commitments” and track record provide no assurance that the Debtor intends to produce certain requested information at all—or produce all of the information, including the privilege logs describing the information the Debtor withholds—on a schedule that affords the Claimants’ Representatives adequate time to analyze the information available only through discovery. 2. The Motion seeks finality for the Debtor to produce all documents responsive to the Requests. The Claimants’ Representatives cannot accept further equivocation from the Debtor and ask that this Court set September 24 as the date for the Debtor to complete its response to the Requests (including the production of all privilege logs). 3. The September 24 date is not a “new deadline” as the Debtor contends.4 It is 45 days from the date (August 10, 2021) that the Debtor represented to this Court that it would substantially complete some categories of documents, which is the implicit deadline under the CMO5 for actual completion of the production of those categories of documents. The CMO implicitly requires actual completion of document production by no later than 45 days from the date of substantial completion, i.e., the date that the privilege logs are due. It would make no sense for the CMO to permit the Debtor to continue producing documents after the date that the privilege log is due. 4. The September 24 date, or another reasonable date for the Debtor to fully complete its response to the Requests and produce its privilege logs, necessarily requires the remainder of the upcoming deadlines in the CMO to be revised. The Debtor has suggested modification of the CMO deadlines by 90 days. The Claimants’ Representatives, however, 4 Objection, at p. 1. 5 Capitalized terms not otherwise defined herein shall have the meanings ascribed to them in the Motion. 8524395.2

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believe a 90-day extension is unreasonable and prejudices pending and future claimants. Even assuming the Debtor produces documents responsive to all outstanding Requests by September 30 with privilege logs being produced 45 days thereafter (November 15), a 90-day extension of the CMO deadlines is completely unworkable. Even the Debtor’s caveated commitments to production would require the end of fact discovery to be moved no less than 180 days. In light of this and the Debtor’s discovery practices to date, even if the Court grants the Claimants’ Representatives requested relief to order production by September 24, there will still need to be an appropriate adjustment to the remaining dates in the CMO, including the anticipated trial date to accommodate the realities of this case. 5. Under the CMO, the Claimants’ Representatives should have had all documents and privilege logs related to the Requests in their possession by no later than August 13, 2021. All fact discovery (including depositions) was to be completed a month and a half later, by September 30. Even if the Claimants’ Representatives could rely upon the Debtor’s caveated commitments to production, the Debtor has not committed to a date certain by which the Claimants’ Representatives will have in their possession all documents responsive to the Requests, including complete privilege logs identifying all documents responsive to the Requests but not produced. Absent finality of the response to the Requests, including the production of all documents and privilege logs by September 24, or another reasonable date to be set by the Court, the remainder of the schedule cannot be set. 6. The Claimants’ Representatives’ foremost objective in this litigation is to protect the interests and due process rights of current and future mesothelioma victims. The Debtor and Georgia-Pacific have been preparing for this estimation proceeding for at least four years and have access to information acquired over the last forty years of litigating these issues in the tort 8524395.2

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system. In contrast, the Claimants’ Representatives require discovery to obtain the information necessary to prepare for this estimation proceeding. The Debtor earlier assured the Court, and the Claimants’ Representatives, that it was “prepared and ready” and would be able to try estimation” within fourteen months. That assurance has proven empty. The Debtor must be compelled to fully complete its production, including privilege logs, in response to the Requests by a date certain before the remainder of the schedule can be set with dates that will allow the Claimants’ Representative to fairly present a defense to the Debtor’s estimation case that has been years in the making. 7. The Claimants’ Representatives respectfully request that the Court grant the Motion and set September 24, or another reasonable date, as the date certain for the Debtor to complete its response to the Requests, including production of all documents and privilege logs. ARGUMENT A. The Debtor’s Objection misstates the discovery record. 8. The Debtor goes to great lengths to frame itself as fully “transparent” in discovery,6 but the discovery record, the record of the July 22, 2021 hearing, and the Objection itself demonstrate the exact opposite. The following misstatements in the Objection are worthy of particular note. B. The Debtor has never “committed” to production by September 30. 9. The Debtor maintains that the Motion was unnecessary because the Debtor “has already committed to complete its production by September 30” and that “no motion was necessary to secure that commitment.”7 The Debtor further attempts to fault the “Claimants 6 E.g., Objection, at ¶ 6. 7 Id. at p.1. 8524395.2

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Representatives” for “simply . . . not ask[ing] before filing.”8 To be clear, before the Motion was filed, the Debtor offered no assurance of production, let alone an assurance of production by a date certain. It was only on August 10, after the Motion was filed, that the Debtor first introduced a prospective date for production (September 30), and even then, the Debtor did not commit to production by that date.9 The Debtor represented only that it was “expect[ing] to compete [sic] our production” by September 30.10 But expecting is not committing. In its Objection, the Debtor now relies solely upon that August 10 communication as evidence of its “commitment.”11 C. The ESI search terms relating to Request 42 are not “new.” 10. The Debtor strains to frame the ESI search terms relating to Request 42 that are the subject of this Motion12 as “new.”13 These search terms are not new. As the Debtor admits, the development of search terms was an iterative process, with the Debtor “serially” providing the search terms it was running and “time and time again” accepting “requests for modifications thereto.”14 The Claimants’ Representatives provided the search terms for Request 42 to the Debtor no less than two months ago—on June 21.15 And the search terms have been the subject of extensive meet and confer discussions between the parties since. 8 Id. 9 See Objection, at Ex. A. 10 Id. 11 See Objection, at ¶¶ 24, 26. Even accepting that the August 10 communication as more of a “commitment” than it was, the Debtor still carved out privilege logs from its unilaterally selected, September 30, date. See Objection, at Ex. A (“[We] expect to compete [sic] our production of non-privileged responsive documents . . . by September 30[.]”) (emphasis added). This carve out was confirmed during a meet and confer on August 10, 2021. 12 See Motion, at ¶ 19(c). 13 Objection, at ¶ 2. 14 Objection, at ¶ 6(c). 15 Email from S. Zieg to J. Jones, et al., dated June 21, 2021 (attaching search terms), attached hereto as Exhibit 1. 8524395.2

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E. The Debtor has not been “transparent” in discovery. 11. The Debtor maintains that “there can be no confusion” about the scope of its production because it has been wholly “transparent” throughout the discovery process.16 The Old GP Funded Medical Studies (Requests 22-23) that are subject of this Motion17 are a prime example of the Debtor’s less than “transparent” discovery efforts in this litigation. In response to Requests 22 and 23, directed to discovery concerning those Old GP Funded Medical Studies, the Debtor affirmed on May 17, 2021 that it would “produce non-privileged documents responsive to the Request[s].”18 The Claimants’ Representatives only later learned that was not the case. On July 16, 2021, the Claimants’ Representatives’ counsel contacted the Debtor to confirm the scope of Debtor’s collection of responsive documents.19 It was only in response to that outreach that the Debtor confirmed that it was standing on its “relevance and proportionality” objections and not producing the full scope of documents responsive to the requests.20 If the Claimants’ Representatives had not inquired, they would have been unaware that the Debtor was blocking responsive discovery directed to the Old GP Funded Medical Studies. The Debtor’s discovery tactics are opaque, not “transparent.” 16 Objection, at ¶ 6. 17 See Motion, at ¶ 19(b). 18 Motion, at Ex. B, p. 17. 19 Email from S. Zieg to J. Jones, et al., dated July 16, 2021, attached to Appendix A to Motion. (Item No. 20) (“[C]an you please provide an overview of the Debtor’s efforts to collect, review, and produce Documents responsive to Request 22 and 23[.]”). 20 Email from J. Jones to S. Zieg, et al., dated July 20, 2021, attached to Appendix A to Motion (Item No. 20). 8524395.2

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F. The deadline for substantial completion of discovery concerning the Sample Resolved Mesothelioma Claims was not extended to August 10. 12. In defense to the Motion, the Debtor rehashes its Extension Motion21 argument that the deadline for substantial completion of the claims file discovery is August 10 rather than June 29, 2021 (the default deadline under the CMO).22 At this point, the Debtor’s argument is simply irrelevant as the Debtor has failed to meet even the August 10 deadline. However, it bears noting that the Debtor’s stated rationale for the extended deadline is flatly contradicted by the record. The Debtor contends that the deadline should be extended to August 10 because the full set of the Sample Resolved Mesothelioma Claims (the “Sample Claims”) was not identified to the Debtor until May 27, 2011.23 The flaw with the Debtor’s reasoning is that any delay was wholly of the Debtor’s own making. The Claimants’ Representatives repeatedly engaged with the Debtor in an effort to identify the Sample Claims, and the Debtor repeatedly delayed in providing the information necessary to facilitate the identification of the Sample Claims.24 13. Counsel for the Claimants’ Representatives first contacted the Debtor on April 13, 2021 (even before the Requests were served) to obtain information necessary to identify the Sample Claims.25 Counsel repeatedly engaged with the Debtor’s counsel thereafter with limited success.26 Only on May 12, 2021, a month after the Claimants’ Representatives initiated the 21 Debtor's Motion to Set Date for Substantial Completion of Document Production [Dkt. 1841] (the “Extension Motion”). 22 Objection, at § II.A, n.5. 23 Id. 24 See generally Appendix A to Motion (Item Nos. 2, 6, 7). 25 Email from S. Zieg to S. Pratt, et al., dated April 13, 2021, attached to Appendix A to Motion (Item No. 2) 26 See, e.g., email from S. Zieg to S. Pratt, et al., dated May 6, 2021, attached to Appendix A to Motion (Item No. 2) (“Stuart, Can you please get back to me on this today. We are hoping to provide the Debtor with guidance on responding to our RFPs”); see also email from S. Zieg to S. Pratt, et al., dated May 7, 2021, attached to Appendix A to Motion (Item No. 6) (“[O]ur ability to define this term [“Sample Resolved Mesothelioma Claims] . . . is contingent on obtaining the additional information I requested last week.”); email from S. Zieg to S. Pratt, et al., 8524395.2

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discussion, did the Debtor finally supply the metrics necessary to identify the Sample Claims.27 The delay in identifying the Sample Claims was wholly of the Debtor’s making. G. The Motion is neither “needless” nor “moot.” 14. In its Objection, the Debtor goes to great lengths to characterize the Motion as “needless when it was filed”28 or “moot.”29 Neither is the case. 15. In framing the Motion as “needless,” the Debtor strains to suggest that it had already committed to produce all the discovery that is the subject of the Motion, before the Motion was filed. To advance its argument that the Motion was “needless” the Debtor repeatedly cites to the email dated August 10, 2021, which the Debtor uses to frame itself as having “committed” to provide discovery responsive to the Motion “on or before September 30.”30 As an initial matter, for the reasons already stated above,31 the August 10 communication fell far short of a “commitment” to production by a date certain.32 But, even accepting that “commitment” as more than it was, it came only after the Claimants’ Representatives filed the Motion on August 6. 17. Even more importantly, in framing the Motion as “moot,” the Debtor ignores that it has not, in fact, committed to production by September 30 for all of the documents that are the subject of the Motion. For the ESI searches associated with the Sample Claims (which are the dated May 11, 2021, attached to Appendix A to Motion (Item No. 7) (“after we receive the information we requested related to [the Sample Resolved Mesothelioma Claims] . . . we will decide how to proceed from there.”). 27 Email from S. Pratt to S. Zieg, et al., dated May 12, 2021, attached hereto as Exhibit 2. 28 Objection, at ¶ 5. 29 Id. at ¶ 28. 30 See id. at ¶¶ 4, 14, 20, 23, 24, 27, and 36. 31See supra Section I.A. 32 Objection, at Ex. A (“[We] expect to compete [sic] our production . . . by September 30, 2021.”) (emphasis added). 8524395.2

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subject the Motion33), the Debtor offers nothing beyond a vague commitment that it will “take on the burden of reviewing documents” that hit upon the requested searches.34 The Debtor offers no commitment to production, and the Debtor certainly offers no commitment to production by a particular date.35 For the ESI searches associated with the Old GP Funded Medical Studies (which are also the subject of the Motion36), the Debtor represents only that it will “review for responsiveness and privilege”—offering no commitment to production, nor production by any date.37 At best, the Debtor has offered only a vague representation that it “expect[s] to compete [sic] production” by September 30.38 That is not a commitment. And even that non-commitment is further caveated by the fact that the Debtor has excluded privilege logs from its unilaterally proposed September 30 date.39 18. The Motion is neither “moot” nor “unnecessary.” It remains as necessary now as it was on August 6 (when the Motion was filed) to ensure the Debtor’s compliance with its discovery obligations. H. To the extent the Debtor is standing on any objections, those objections are waived. 19. In its Objection, the Debtor argues that it did not waive any objections as to relevance and scope by failing to state in its discovery responses whether it was withholding 33 Motion, at ¶ 19.a(iii). 34 Objection, at ¶ 21. 35 Id. 36 Motion, at ¶ 19.b(i). 37 Objection, at ¶ 22. 38 Id. at Ex. A. 39 See id. (“[We] expect to compete [sic] our production of non-privileged documents . . . by September 30[.]”) (emphasis added). 8524395.2

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documents based on any objections.40 As an initial matter, the fact that the Debtor is still attempting to preserve its objections as to scope and relevance belies its contentions of transparency and its statements that it intends to produce all non-privileged, responsive documents. If the Debtor truly intended to produce all responsive documents, then there would be no need for it to argue so strenuously that it had not waived those objections. 20. More fundamentally, the Debtor’s argument is incorrect. According to the Debtor, it “cannot be and is not the law” that a party must identify the documents being withheld on the basis of an objection as to proportionality because to do so would be too difficult.41 This argument ignores the plain language of Rule 34 and the advisory committee notes to the 2015 amendments to the rule.42 21. Putting aside the fact that the Debtor’s argument ignores the express requirements of Rule 34, the Debtor’s concern is addressed by the advisory committee notes to the 2015 amendments to Rule 34. The advisory notes explain that a party can satisfy the requirement to disclose whether documents are being withheld by specifying the sources that will be searched and the timeframe covered by the search.43 The Debtor did not satisfy this requirement when it responded to the Requests. The Debtor’s complete response to Request 22, which calls for the 40 Id. at ¶ 31. 41 Id. 42 Fed. R. Civ. P 34(b)(2)(c) (stating that “an objection must state whether any responsive materials are being withheld on the basis of that objection” (emphasis added)). 43 See Advisory Committee Note to 2015 Amendments to Fed. R. Civ. P. 34 (“The producing party does not need to provide a detailed description or log of all documents withheld, but does need to alert other parties to the fact that documents have been withheld and thereby facilitate an informed discussion of the objection. An objection that states the limits that have controlled the search for responsive and relevant materials qualifies as a statement that the materials have been ‘withheld.’”) and (“Examples would be a statement that the responding party will limit the search to documents or electronically stored information created within a given period of time prior to the events in suit, or to specified sources. When there is such an objection, the statement of what has been withheld can properly identify as matters ‘withheld’ anything beyond the scope of the search specified in the objection.”). 8524395.2

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production of documents relating to the Old GP Funded Medical Studies, provides a perfect example: Bestwall objects to this Request because it seeks information that is neither relevant nor proportional to the needs of the case. Bestwall also objects to this Request on the ground that it seeks information subject to the attorney-client privilege, work product doctrine, and/or other applicable protections from disclosure. Subject to and without waiving its objections, Bestwall will produce nonprivileged documents responsive to this Request.44 22. The Debtor provided no rationale for its boilerplate objections and did not state whether it was withholding any documents based on those objections. Nor did the Debtor describe the searches that it would perform to find responsive documents. Thus, the Claimants’ Representatives were left to question what documents were actually being produced, what sources the Debtor searched, and what if any documents were being withheld on the basis of the objections. 23. The Debtor contends that these questions are now irrelevant because it subsequently provided a chart containing this information.45 However, the Debtor produced this chart only after repeated attempts by the Claimants’ Representatives to have a meet and confer to discuss each of the Requests and the Debtor’s responses thereto. Even when the chart was provided, it did not confirm that documents determined to be responsive would in fact be produced notwithstanding the general objections.46 That is exactly the process that the 2015 amendment to Rule 34 was designed to prevent.47 Thus, the Debtor is incorrect when it states 44 See Discovery Responses attached as Exhibit B to Motion, at Response No. 22. 45 Objection, at ¶ 29. 46 See Motion, Appendix A (Item No. 27). 47 As stated in the Advisory Committee Notes, the amendment requiring a party to specify whether documents are being withheld on the basis of an objection “should end the confusion that frequently arises when a producing party states several objections and still produces information, leaving the requesting party uncertain whether any relevant 8524395.2

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that the information it recently provided “exceeds any disclosure obligation” imposed by Rule 34.48 24. Courts have consistently held that a party waives objections when it fails to comply with Rule 34.49 The Debtor did not attempt to counter the cases stating that “boilerplate objections without specifying exactly what information is being withheld” are “text-book examples of what federal courts have routinely deemed to be improper objections.”50 Instead, the Debtor discussed only one of the cases cited by the Claimants’ Representatives in the Motion, and it completely misreads that case. 25. The Debtor contends that the case of Mr. Dees’ Inc. v. Inmar, Inc, 1:10CV141 2020 WL 6488700 (M.D.N.C. Nov. 4, 2020), does not support the proposition that a party waives objections by failing to respond as required by Rule 34.51 That is incorrect. In Mr. Dees, the defendants objected to discovery requests by asserting that, among other things, the requests were unreasonably burdensome and expensive.52 However, the defendants stated that they would produce documents “[s]ubject to and without waiving these objections.”53 On a motion to compel, the court concluded that the discovery responses did not adequately state objections or and responsive information has been withheld on the basis of the objections.” See Advisory Committee Note to 2015 Amendments to Fed. R. Civ. P. 34. 48 Objection, at ¶ 30. 49 See Kinetic Concepts, Inc. v. ConvaTec Inc., 268 F.R.D. 226, at 247 (M.D.N.C. 2010) (“By failing to present valid objections to these discovery requests, Plaintiffs ‘waived any legitimate objection [they] may have had.’”); Fidelity Nat’l Title Ins. Co. v. Barringer Land SC, LLC, No. 2:13-cv-69, 2014 WL 12594207, at *1 (N.D.W. Va. April 15, 2014) (“As the Court has stated numerous times, boilerplate objections to discovery requests are highly disfavored in this district and throughout the Fourth Circuit, and the failure to state objections with specificity may be regarded as a waiver of those objections.”); Mr. Dees’ Inc. v. Inmar, Inc, 1:10CV141, 2020 WL 6488700, at * 7 (M.D.N.C. Nov. 4, 2020) (“Defendants ‘fail[ed] to present valid objections to the [ACPTD R]equest [and thereby] “waived any legitimate objection [they] may have had[.]”’’). 50 Fidelity Nat’l Title, 2014 WL 12594207, at *2. 51 Objection, at ¶ 33. 52 Id. at *2. 53 Id. 8524395.2

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otherwise comply with Rule 34.54 The court recognized the provisions of Rule 34 that required that objections be stated with specificity and that an objection must state whether any responsive materials are being withheld on the basis of the objection.55 The court ultimately concluded that “Defendants failed to present valid objections to the [document] request and thereby waived any legitimate objection they may have had.”56 26. The reasoning applied in Mr. Dees is directly applicable here. The Debtor asserted boilerplate objections without specifying the basis for the objection. The Debtor then said it would produce responsive documents subject to, and without waiving, those objections. The Debtor failed to state whether it was withholding any documents based on those objections. Therefore, the Debtor failed to comply with Rule 34 and “thereby waived any legitimate objection [it] may have had.”57 CONCLUSION WHEREFORE, the Claimants’ Representatives respectfully request that the Court enter an order compelling the Debtor to complete its response to the Requests, including production of all documents and all privilege logs, by no later than September 24, 2021, or an alternative date certain that affords the Claimants’ Representatives adequate time to fairly develop their case in the estimation proceeding. 54 Id. at *6. 55 Id. 56 Id. at *7 (internal quotations omitted). 57 Id. 8524395.2

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Dated: August 26, 2021 Respectfully submitted, HAMILTON STEPHENS STEELE ALEXANDER RICKS PLLC + MARTIN, PLLC /s/ Glenn C. Thompson /s/ Felton E. Parrish Glenn C. Thompson (NC Bar No. 37221) Felton E. Parrish (NC Bar No. 25448) 525 North Tyron Street, Suite 1400 1420 E. 7th Street, Suite 100 Charlotte, North Carolina 28202 Charlotte, NC 28204 Telephone: (704) 344-1117 Telephone: 704-365-3656 Facsimile: (704) 344-1483 Facsimile: 704-365-3676 Email: gthompson@lawhssm.com Email: felton.parrish@alexanderricks.com -and- -and- Linda W. Simpson (Bar No. 12596) James L. Patton, Jr. (DE Bar No. 2202) JD THOMPSON LAW Edwin J. Harron (DE Bar No. 3396) Post Office Box 33127 Sharon M. Zieg (NC Bar No. 29536) Charlotte, North Carolina 28233 Erin D. Edwards (DE Bar No. 4392) Telephone: (828) 489-6578 YOUNG CONAWAY STARGATT & Email: lws@jdthompsonlaw.com TAYLOR, LLP Rodney Square -and - 1000 North King Street Wilmington, Delaware 19801 Natalie D. Ramsey (DE Bar No. 5378) Telephone: (302) 571-6600 Davis Lee Wright (DE Bar No. 4324) Facsimile: (302) 571-1253 ROBINSON & COLE LLP Email: jpatton@ycst.com 1201 North Market Street, Suite 1406 eharron@ycst.com Wilmington, Delaware 19801 szieg@ycst.com Telephone: (302) 516-1700 eedwards@ycst.com Email: nramsey@rc.com dwright@rc.com Counsel to the Future Claimants’ Representative Counsel to the Official Committee of Asbestos Creditors 8524395.2

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