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Full title: Amended Disclosure Statement [Second Amended Disclosure Statement for Second Amended Joint Chapter 11 Plan of Liquidation Proposed by Debtors and Official Committee of Unsecured Creditors, as Modified] [REDLINED VERSION] Filed by Debtor Freedom Communications, Inc. (RE: related document(s)1653 Disclosure Statement For Joint Chapter 11 Plan Of Liquidation Proposed By Debtors And Official Committee Of Unsecured Creditors Filed by Debtor Freedom Communications, Inc., Creditor Committee Official Committee of Unsecured Creditors. (Dulberg, Jeffrey) - Warning: See docket entry no.: 1659 for corrections - Modified on 6/5/2020 (Bolte, Nickie). [ORDER SHORTENING TIME GRANTED 6/9/2020. HEARING ON MOTION SET FOR JULY 15, 2020 AT 2:00 P.M. IN COURTROOM 6C - ATTORNEY TO GIVE NOTICE] Modified on 6/9/2020.). (Friedman, Alan) (Entered: 05/06/2021)

Document posted on May 5, 2021 in the bankruptcy, 63 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Allowed Miscellaneous Secured Claim shall receive, in satisfaction, settlement, and release of, and in exchange 18 such Miscellaneous Secured Claim, (x) payment in full in C of the unpaid portion of such Allowed Miscellaneous Secu 19 Claim, (y) the collateral securing such Allowed MiscellaneSecured Claim, or (z) such other treatment as may be agree by the Holder of such Claim and the Debtors or the Liquidat 20 Debtors. Treatment: Except to the extent that a Holder of an Allowed Miscellaneous SecureClaim has been paid by the Debtors, in whole or in part, prior to the Effective Date, on the later o15 (i) the Effective Date and (ii) thirty (30) calendar days following the date on which such MiscellaneouSecured Claim becomes an Allowed Miscellaneous Secured Claim, at the option of the Liquidatin16 Debtors, in full and final satisfaction of such Miscellaneous Secured Claim, (i) each AlloweMiscellaneous Secured Claim shall be reinstated and Unimpaired in accordance with section 1124 o17 the Bankruptcy Code, or (ii) each Holder of an Allowed Miscellaneous Secured Claim shall receiv18 in full satisfaction, settlement, and release of, and in exchange for, such Miscellaneous Secured Clai(x) payment in full in Cash of the unpaid portion of such Allowed Miscellaneous Secured Claim, (y19 the collateral securing such Allowed Miscellaneous Secured Claim, or (z) such other treatment as mabe agreed to by the Holder of such Claim and the Debtors or the Liquidating Debtors.The Plan Administrator shall serve in such capacity through the earlier of the dat6 that all of the Debtors are dissolved in accordance with the Plan and the date such Plan Administratresigns, is terminated or otherwise unable to serve; provided, however, that any successor Pla7 Administrator appointed pursuant to the Plan shall serve in such capacity after the effective date such person’s appointment as Plan Administrator.If the rejection of an executory contract or unexpired lease pursuant to the Plan or otherwisgives rise to a Claim by the other party or parties to such contract or lease, such Claim shall be forev10 barred and shall not be enforceable against the Debtors or their Estates unless a proof of Claim is Fileand served on the Plan Administrator and its counsel within thirty (30) calendar days after the earlie11 of (a) the Effective Date and (b) service of a notice that the executory contract or unexpired lease habeen rejected.Notwithstanding any other provision of the Plan, in the Plan Administrator’s sole discretio14 the Plan Administrator will not be required to make distributions of Cash less than $25 in value, aneach such Claim to which this limitation applies shall be deemed fully and finally satisfied and n15 entitled to any further payment or consideration pursuant to Article IX and its Holder is forever barrepursuant to Article IX from asserting that Claim or Claims against the Debtors, the Liquidatin16 Debtors, their Estates, or their property.

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1 R o b e r t J . F e i n s t e i n ( P r o H a c V i c e ) Alan J. Friedman (Bar No. 132580) Jeffrey W. Dulberg (Bar No. 181200) 2 SHULMAN BASTIAN FRIEDMAN & BUI PACHULSKI STANG ZIEHL & JONES LLP LLP 10100 Santa Monica Blvd., 13th Floor 3 100 Spectrum Center Drive, Suite 600 Los Angeles, CA 90067 Irvine, California 92618 Telephone: (310) 277-6910 4 Telephone: (949) 340-3400 Facsimile: (310) 201-0760 Facsimile: (949) 340-3000 Email: rfeinstein@pszjlaw.com 5 Email: afriedman@shulmanbastian.com akornfeld@pszjlaw.com jdulberg@pszjlaw.com 6 Counsel for the Debtors Co-Plan Proponents Counsel for the Official Committee of 7 Unsecured Creditors, Co-Plan Proponents 8 9 10 UNITED STATES BANKRUPTCY COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 SANTA ANA DIVISION 13 In re: Case No.: 8:15-bk-15311-MW 14 FREEDOM COMMUNICATIONS, INC., a Chapter 11 Delaware corporation, et al.,1 15 (Jointly Administered with Case Nos. Debtors and 8:15-bk-15312-MW; 8:15-bk-15313-MW; 16 Debtors-in-Possession. 8:15-bk-15315-MW; 8:15-bk-15316-MW; 8:15-bk-15317-MW; 8:15-bk-15318-MW; 17 8:15-bk-15319-MW; 8:15-bk-15320-MW; 8:15-bk-15321-MW; 8:15-bk-15322-MW; 18 8:15-bk-15323-MW; 8:15-bk-15324-MW; 8:15-bk-15325-MW; 8:15-bk-15326-MW; 19 8:15-bk-15327-MW; 8:15-bk-15328-MW; 8:15-bk-15329-MW; 8:15-bk-15330-MW; 20 8:15-bk-15332-MW; 8-15-bk-15337-MW; 8:15-bk-15339-MW; 8-15-bk-15340-MW; 21 8:15-bk-15342-MW; 8:15-bk-15343-MW) 22 23 1 The last four digits of the Debtors’ federal tax identification numbers are as follows: Freedom Communications, In24 (0750); Freedom Communications Holdings, Inc. (2814); Freedom Services, Inc. (3125); 2100 Freedom, Inc. (7300); OCCommunity Publications, Inc. (9752); Daily Press, LLC (3610); Freedom California Mary Publishing, Inc. (412125 Freedom California Ville Publishing Company LP (7735); Freedom Colorado Information, Inc. (7806); FreedoInteractive Newspapers, Inc. (9343); Freedom Interactive Newspapers of Texas, Inc. (8187); Freedom Newspap26 Acquisitions, Inc. (4322); Freedom Newspapers (7766); Freedom Newspapers, Inc. (3240); Freedom Newspapers Southwestern Arizona, Inc. (5797); OCR Information Marketing, Inc. (7983); Odessa American (7714); Orange Count27 Register Communications, Inc. (7980); Victor Valley Publishing Company (6082); Victorville Publishing Compan(7617); Freedom SPV II, LLC (8253); Freedom SPV VI, LLC (8434); Freedom SPV I, LLC (3293); Freedom SPV ILLC (8500); and Freedom SPV V, LLC (9036). The Debtors’ mailing address is 625 N. Grand Avenue, Santa An28

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1 SECOND AMENDED DISCLOSURE STATEMENT FOR SECOND AMENDED 2 Affects: JOINT CHAPTER 11 PLAN OF LIQUIDATION PROPOSED BY 3 All Debtors DEBTORS AND OFFICIAL COMMITTEE OF UNSECURED CREDITORS, AS 4 Freedom Communications, Inc., a Delaware MODIFIED corporation, ONLY 5 Freedom Communications Holdings, Inc., a Disclosure Statement Approval Hearing: 6 Delaware corporation, ONLY Date: April 28, 2021 Time: 2:00 p.m. 7 Freedom Services, Inc., a Delaware Place: Courtroom 6C corporation, ONLY 411 West Fourth Street 8 Santa Ana, CA 92701 2100 Freedom, Inc., a Delaware 9 corporation, ONLY Judge: Honorable Mark S. Wallace 10 OCR Community Publications, Inc., a California corporation, ONLY 11 Daily Press, LLC, a California limited 12 liability company, ONLY 13 Freedom California Mary Publishing, Inc., a California corporation, ONLY 14 Freedom California Ville Publishing 15 Company LP, a California limited partnership, ONLY 16 Freedom Colorado Information, Inc., a 17 Delaware corporation, ONLY 18 Freedom Interactive Newspapers, Inc., a California corporation, ONLY 19 Freedom Interactive Newspapers of Texas, 20 Inc., a Delaware corporation, ONLY 21 Freedom Newspaper Acquisitions, Inc., a Delaware corporation, ONLY 22 Freedom Newspapers, a Texas general 23 partnership, ONLY 24 Freedom Newspapers, Inc., a Delaware corporation, ONLY 25 Freedom Newspapers of Southwestern 26 Arizona, Inc., a California corporation, ONLY 27 OCR Information Marketing, Inc., a California corporation, ONLY 28

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1 Odessa American, a Texas general partnership, ONLY 2 Orange County Register Communications, Inc., a California corporation, ONLY 3 Victor Valley Publishing Company, a 4 California corporation, ONLY 5 Victorville Publishing Company, a California limited partnership, ONLY 6 Freedom SPV II, LLC, a Delaware limited 7 liability company, ONLY 8 Freedom SPV VI, LLC, a Delaware limited liability company, ONLY 9 Freedom SPV I, LLC, a Delaware limited 10 liability company, ONLY 11 Freedom SPV IV, LLC, a Delaware limited liability company, ONLY 12 Freedom SPV V, LLC, a Delaware limited 13 liability company, ONLY 14 15 THIS IS NOT A SOLICITATION OF VOTES ON THE PLAN. VOTES MAY NOT BE SOLICITED UNTIL THE BANKRUPTCY COURT HAS APPROVED A DISCLOSURE 16 STATEMENT. THIS DISCLOSURE STATEMENT IS BEING SUBMITTED FOR APPROVAL BUT HAS NOT YET BEEN APPROVED BY THE BANKRUPTCY COURT. 17 THE INFORMATION IN THIS DISCLOSURE STATEMENT IS SUBJECT TO CHANGE. 18 THIS DISCLOSURE STATEMENT IS NOT AN OFFER TO SELL ANY SECURITIES ANIS NOT SOLICITING AN OFFER TO BUY ANY SECURITIES. 19 20 21 22 23 24 25 26 27 28

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1 DISCLAIMER 2 THIS DISCLOSURE STATEMENT PROVIDES INFORMATION REGARDING THJOINT CHAPTER 11 PLAN OF LIQUIDATION PROPOSED BY TH 3 DEBTORS AND OFFICIAL COMMITTEE OF UNSECURED CREDITORS THAT THDEBTORS AND THE COMMITTEE ARE SEEKING TO HAVE CONFIRMED BY TH4 BANKRUPTCY COURT. THE INFORMATION CONTAINED IN THIS DISCLOSUR5 STATEMENT IS INCLUDED FOR PURPOSES OF SOLICITING ACCEPTANCES TO, ANCONFIRMATION OF, THE PLAN AND MAY NOT BE RELIED ON FOR ANY OTHE6 PURPOSE. APPROVAL OF THIS DISCLOSURE STATEMENT DOES NOT CONSTITUTA DETERMINATION OR RECOMMENDATION BY THE BANKRUPTCY COURT AS T7 THE FAIRNESS OR THE MERITS OF THE PLAN. 8 THIS DISCLOSURE STATEMENT CONTAINS SUMMARIES OF CERTAIN PROVISION9 OF THE PLAN, CERTAIN STATUTORY PROVISIONS, CERTAIN DOCUMENTRELATING TO THE PLAN, AND CERTAIN FINANCIAL INFORMATION. ALTHOUG10 THE PLAN PROPONENTS BELIEVE THAT THESE SUMMARIES ARE FAIR ANACCURATE AND PROVIDE ADEQUATE INFORMATION WITH RESPECT TO TH11 DOCUMENTS SUMMARIZED, SUCH SUMMARIES ARE QUALIFIED TO THE EXTENTHAT THEY DO NOT SET FORTH THE ENTIRE TEXT OF, OR ARE INCONSISTEN12 WITH, SUCH DOCUMENTS. 13 ALTHOUGH THE PLAN PROPONENTS HAVE MADE EVERY EFFORT TO B14 ACCURATE, THE FINANCIAL INFORMATION CONTAINED HEREIN HAS NOT BEETHE SUBJECT OF AN AUDIT OR OTHER REVIEW BY AN ACCOUNTING FIRM. I15 THE EVENT OF ANY CONFLICT, INCONSISTENCY, OR DISCREPANCY BETWEETHE TERMS AND PROVISIONS IN THE PLAN, THIS DISCLOSURE STATEMENT, TH16 EXHIBITS ANNEXED TO THIS DISCLOSURE STATEMENT, OR THE FINANCIA17 INFORMATION INCORPORATED HEREIN OR THEREIN BY REFERENCE, THE PLASHALL GOVERN FOR ALL PURPOSES. ALL HOLDERS OF CLAIMS SHOULD REA18 THIS DISCLOSURE STATEMENT AND THE PLAN IN THEIR ENTIRETY BEFORVOTING ON THE PLAN. 19 THE STATEMENTS AND FINANCIAL INFORMATION CONTAINED HEREIN HAV20 BEEN MADE AS OF THE DATE HEREOF UNLESS OTHERWISE SPECIFIED. HOLDEROF CLAIMS AND INTERESTS REVIEWING THIS DISCLOSURE STATEMENT SHOUL21 NOT INFER AT THE TIME OF SUCH REVIEW THAT THERE HAVE BEEN N22 CHANGES IN THE FACTS SET FORTH HEREIN. ALTHOUGH THE PLAPROPONENTS HAVE MADE AN EFFORT TO DISCLOSE WHERE CHANGES I23 PRESENT CIRCUMSTANCES COULD REASONABLY BE EXPECTED TO AFFECMATERIALLY THE RECOVERY UNDER THE PLAN, THIS DISCLOSURE STATEMEN24 IS QUALIFIED TO THE EXTENT CERTAIN EVENTS DO OCCUR. 25 26 27 28

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1 THIS DISCLOSURE STATEMENT HAS BEEN PREPARED IN ACCORDANCE WITSECTION 1125 OF THE BANKRUPTCY CODE AND NOT NECESSARILY I2 ACCORDANCE WITH FEDERAL OR STATE SECURITIES LAWS OR OTHER NOBANKRUPTCY LAW. THIS DISCLOSURE STATEMENT HAS NOT BEEN APPROVE3 OR DISAPPROVED BY THE SECURITIES AND EXCHANGE COMMISSION (THE “SEC4 OR ANY FEDERAL, STATE, LOCAL, OR FOREIGN REGULATORY AGENCY, NOR HATHE SEC OR ANY OTHER SUCH AGENCY PASSED UPON THE ACCURACY O5 ADEQUACY OF THE STATEMENTS CONTAINED IN THIS DISCLOSURE STATEMENPERSONS OR ENTITIES HOLDING OR TRADING IN, OR OTHERWISE PURCHASIN6 SELLING, OR TRANSFERRING, CLAIMS AGAINST THE DEBTORS SHOULEVALUATE THIS DISCLOSURE STATEMENT AND THE PLAN IN LIGHT OF TH7 PURPOSE FOR WHICH THEY WERE PREPARED. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 TABLE OF CONTENTS 2 Page( 3 4 I. INTRODUCTION .............................................................................................................11 5 II. PLAN OVERVIEW ...........................................................................................................11 6 A. General Structure of the Plan .................................................................................11 B. Summary of Treatment of Claims and Interests Under the Plan ...........................12 7 C. Plan Voting Instructions and Procedures ...............................................................14 8 1. Voting Rights .............................................................................................14 9 2. Solicitation Materials .................................................................................15 10 3. Voting Instructions and Procedures ...........................................................16 11 12 4. Confirmation Hearing and Deadline for Objections to Confirmation .......18 III. GENERAL INFORMATION ABOUT THE DEBTORS AND THE CASES .................19 13 A. Business Overview and Background .....................................................................19 14 B. Circumstances Leading to Chapter 11 Filing.........................................................20 15 C. Prepetition Secured Debt .......................................................................................20 16 IV. THE CHAPTER 11 CASES ..............................................................................................21 A. First Day Orders .....................................................................................................21 17 B. Cash Collateral / DIP Financing ............................................................................21 18 C. Payment of Prepetition Commission Obligations ..................................................21 19 D. Debtors’ Customer, Subscriber and Advertiser Programs .....................................22 20 E. The Sale of Substantially All of the Debtors’ Assets ............................................22 21 F. The Silver Point Settlement ...................................................................................23 G. The Committee Action ...........................................................................................23 22 H. Claim Bar Dates .....................................................................................................26 23 I. Incentive and Severance Programs ........................................................................26 24 J. Extension of Exclusivity Periods for Filing a Chapter Plan and for Soliciting Acceptances to the Plan .........................................................................................27 25 K. Retention of Debtors’ Professionals ......................................................................27 26 L. Appointment of Committee and Retention of Committee Professionals...............27 27 M. Schedules, Statements of Financial Affairs ...........................................................28 28 N. Prosecution of Avoidance Actions .........................................................................28

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1 V. SUMMARY OF THE JOINT CHAPTER 11 PLAN ........................................................28 2 A. Purpose and Effect of the Plan ...............................................................................28 B. Limited Substantive Consolidation ........................................................................29 3 C. Estimated Recoveries .............................................................................................30 4 VI. CERTAIN PLAN PROVISIONS ......................................................................................30 5 A. Classification and Treatment of Classified Claims and Interests ..........................30 6 1. Summary. ...................................................................................................30 7 2. Classification and Treatment of Claims and Interests. ..............................30 8 B. Acceptance of Rejection of the Plan ......................................................................33 9 1. Classes Permitted and Not Permitted to Vote. ...........................................33 10 2. Effect of Non-Voting. ................................................................................33 11 3. Nonconsensual Confirmation.....................................................................33 12 4. Postpetition Interest. ..................................................................................33 13 5. Elimination of Vacant Classes. ..................................................................33 14 6. Special Provisions Regarding Insured Claims. ..........................................34 15 C. Means for Implementation of the Plan ...................................................................34 16 1. Settlement of Intercompany Claims. ..........................................................34 17 2. Partial Substantive Consolidation. .............................................................34 18 3. Continued Corporate Existence and Vesting of Assets. ............................35 19 4. Corporate Action; Winding Up of Affairs. ................................................36 20 5. Plan Administrator. ....................................................................................37 21 22 6. Source of Funding. .....................................................................................38 23 7. Retained Rights of Action. .........................................................................38 24 8. Interests in Non-Debtors Affiliates and Subsidiaries.................................40 25 9. Payment of Plan Expenses. ........................................................................41 26 10. Dissolution of Debtors; Final Decree. .......................................................41 27 11. Records. .....................................................................................................41 28

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1 D. Treatment of Executory Contracts and Unexpired Leases ....................................41 2 1. Rejection of Executory Contracts and Unexpired Leases. .........................41 3 2. Bar Date for Rejection Claims. ..................................................................42 4 E. Distributions and Related Matters .........................................................................42 5 1. Dates of Distribution. .................................................................................42 6 2. Cash Distributions. .....................................................................................42 7 3. Rounding of Payments. ..............................................................................42 8 4. Disputed Claims. ........................................................................................42 9 5. Undeliverable and Unclaimed Distributions. .............................................43 10 6. Minimum Distributions. .............................................................................43 11 7. Compliance With Tax Requirements. ........................................................43 12 8. Record Date in Respect to Distributions. ...................................................43 13 F. Litigation, Objections to Claims, and Determination of Taxes .............................44 14 1. Litigation. ...................................................................................................44 15 2. Objections to Claims; Objection Deadline. ...............................................44 16 3. Tax Determinations. ...................................................................................44 17 4. Temporary or Permanent Resolution of Disputed Claims. ........................44 18 5. Setoffs. .......................................................................................................45 19 G. Injunctions, Exculpation, Releases and Related Provisions ..................................45 20 1. Injunctions..................................................................................................45 21 2. Exculpation. ...............................................................................................45 22 23 3. Debtor Release. ..........................................................................................46 24 4. Consenting Creditor Release......................................................................46 VII. RISK FACTORS ...............................................................................................................47 25 A. The Plan Proponents May Not Be Able to Obtain Confirmation of the Plan ........47 26 B. Claims May Exceed the Plan Proponents’ Estimates ............................................47 27 C. The Conditions Precedent to the Effective Date of the Plan May Not Occur .......47 28

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1 VIII. CONFIRMATION OF THE PLAN...................................................................................48 2 A. The Confirmation Hearing .....................................................................................48 B. Requirements for Confirmation of the Plan ...........................................................48 3 C. Best Interests of Creditors ......................................................................................49 4 D. Feasibility ...............................................................................................................51 5 E. Acceptance by Impaired Classes ...........................................................................52 6 F. Confirmation Without Acceptance by All Impaired Classes .................................52 7 1. No Unfair Discrimination ..........................................................................52 8 2. Fair and Equitable Test ..............................................................................53 9 G. Alternatives to the Plan ..........................................................................................53 IX. CERTAIN UNITED STATES FEDERAL INCOME TAX CONSEQUENCES OF 10 THE PLAN ........................................................................................................................53 11 A. Federal Taxation Issues Related to Pass-Through Entities in General ..................54 12 B. Consequences to Creditors .....................................................................................55 13 1. Holders of Claims ......................................................................................55 14 2. Non-United States Persons ........................................................................56 15 C. Importance of Obtaining Professional Tax Assistance ..........................................56 X. RECOMMENDATION .....................................................................................................57 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 EXHIBITS 2 EXHIBIT A First Second Amended Joint Plan of Liquidation 3 EXHIBIT B Organizational Chart 4 5 THE PLAN PROPONENTS HEREBY ADOPT AND INCORPORATE EACH EXHIBIT ATTACHED TO THIS DISCLOSURE STATEMENT 6 BY REFERENCE AS THOUGH FULLY SET FORTH HEREIN 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 I. INTRODUCTION 2 Pursuant to title 11 of the United States Code, 11 U.S.C. §§ 101, et seq. (the “BankruptcCode”), the above-captioned debtors and debtors-in-possession (the “Debtors” or the “Company”) an3 the Official Committee of Unsecured Creditors (the “Committee”) hereby jointly submit this firSecond aAmended dDisclosure sStatement (the “Disclosure Statement”) for the First Second Amende4 Joint Chapter 11 Plan of Liquidation Proposed by Debtors and Official Committee of Unsecure5 Creditors (as may be amended or modified, the “Plan”). The definitions contained in the BankruptcCode are incorporated herein by this reference. The definitions set forth in Article II of the Plan wi6 also apply to capitalized terms used herein that are not otherwise defined. A copy of the Plan iattached hereto as Exhibit A.2 7 The purpose of this Disclosure Statement is to enable creditors whose Claims are Impaire8 under the Plan and who are entitled to vote to make an informed decision in exercising their right t9 accept or reject the Plan. This Disclosure Statement sets forth certain information regarding thDebtors’ prepetition operating and financial history, their reasons for seeking protection under chapte10 11 of the Bankruptcy Code, and the anticipated wind-down and liquidation of the Liquidating Debtorby a Plan Administrator. This Disclosure Statement also describes certain terms and provisions of th11 Plan, certain effects of Confirmation of the Plan, certain risk factors associated with the Plan, and thmanner in which Distributions will be made under the Plan. In addition, this Disclosure Stateme12 discusses the Confirmation process and the voting procedures that Holders of Claims entitled to vot13 under the Plan must follow for their votes to be counted. 14 II. PLAN OVERVIEW 15 A. General Structure of the Plan 16 The Debtors and the Committee are co-proponents of the Plan, which provides for thdistribution of the remaining assets of the Debtors’ estates, consisting primarily of net cash proceed17 from certain settlements and the proceeds flowing from a resolution of a dispute with the Californi18 Department of Taxation and Fee Administration (“CDTFA”) regarding potential tax refunds in thapproximate amount of $5 million. Specifically, the Plan provides for the liquidation, collectio19 disposition and distribution of the remaining assets of the Debtors’ Estates and winding-up thDebtors’ affairs and the Chapter 11 Cases. Substantially all of the Debtors’ assets were sold to a thir20 party buyer and the remaining material causes of action of the Debtors were addressed and resolveunder certain settlements including with the Pension Benefit Guaranty Corporation. The Pla21 proposes to fairly and efficiently allocate the Debtors’ remaining Distributable Assets in a manner th22 is supported by the principal constituencies in the Chapter 11 Cases and will allow such cases to bpromptly resolved. 23 The Plan will be implemented through the substantive consolidation of the Debtors’ Estate24 for the purposes of voting and Distributions under the Plan, the re-vesting of the Estates’ assets iLiquidating Debtor Freedom Communications, Inc., and the appointment of a Plan Administrator t25 liquidate or otherwise dispose of the Estates’ remaining assets, if and to the extent such assets wer26 not previously monetized or otherwise transferred by the Debtors prior to the Effective Date. A 27 2 All capitalized terms used but not defined herein shall have the meanings provided to such terms in the Plan. Thsummary of the Plan provided herein is qualified in its entirety by reference to the Plan. In the case of any inconsistenc28

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1 Intercompany Claims will be waived and eliminated. The Plan Administrator will act for thLiquidating Debtors in the same fiduciary capacity as applicable to a board of directors of a Delawar2 corporation implementing such liquidation and wind-down as contemplated under the Plan, subject tthe provisions hereof, and shall, among other powers, wind up the affairs of the Liquidating Debtor3 use, manage, sell, abandon and/or otherwise dispose of the remaining property of the Estate4 prosecute objections to Claims and any litigation on behalf of the Liquidating Debtors; causdistributions to be made to Creditors pursuant to the Plan; and take such other actions required und5 or consistent with the Plan. The initial Plan Administrator will be the current Chief RestructurinOfficer, Brad Smith. 6 Under the Plan, the Holders of Allowed Administrative Expenses, Allowed Priority Ta7 Claims, and Allowed Priority Non-Tax Claims will be paid in full on the Effective Date, unlesotherwise agreed with the Holders of such Claims. The Holders of Allowed Miscellaneous Secure8 Claims will either: (a) be paid in cash up to the value of their collateral, or (b) have their obligation9 assumed or otherwise addressed as provided for in the Plan, including pursuant to agreements witsuch Holders. As discussed in the Disclosure Statement, the Secured Claims of the Debtor10 prepetition secured lenders, the debtor-in-possession financing lenders, and the PBGC were paid ifull or otherwise addressed and resolved prior to the filing of the Plan. 11 Holders of Allowed General Unsecured Claims will receive any remaining Net Distributabl12 Estate Assets after the payment of (or reserves for) Allowed Administrative Expenses, Allowe13 Priority Tax Claims, Allowed Priority Non-Tax Claims, Allowed Miscellaneous Secured Claims, anPlan Expenses; provided that in the event that the aggregate Cash recovery for Holders of Allowe14 General Unsecured Claims (other than the PBGC) exceeds $1,000,000, then any excess Cash proceedwill be shared ratably by the Holders of Allowed General Unsecured Claims and the Holder of th15 PBGC Unsecured Claims. The PBGC (or other Holder of the PBGC Unsecured Claims) will receivthe treatment provided for the PBGC Unsecured Claims set forth in the PBGC Settlement, includin16 as noted, the PBGC sharing ratably with Holders of Allowed Class 3 General Unsecured Claims an17 excess Cash proceeds over $1,000,000 in the aggregate. 18 All Interests in the Debtors will be canceled, and any associated management rights held bHolders of Interests will be void and of no force and effect as of the Effective Date. Holders o19 Interests will not receive any Distribution or other property pursuant to the Plan. 20 THE PLAN PROPONENTS BELIEVE THAT THE PLAN IS FAIR AND EQUITABLWILL MAXIMIZE THE VALUE TO THESE ESTATES, AND IS IN THE BEST INTEREST21 OF THE DEBTORS AND THEIR CONSTITUENTS. 22 FOR THESE REASONS, THE PLAN PROPONENTS URGE HOLDERS OF CLAIM23 WHO ARE ENTITLED TO VOTE TO TIMELY RETURN THEIR BALLOTS AND TO VOTTO ACCEPT THE PLAN. 24 B. Summary of Treatment of Claims and Interests Under the Plan 25 The Plan provides for the classification and treatment of Claims and Interests. The Pla26 designates 4 Classes of Claims and 1 Class of Interests. These Classes and Plan treatments take int27 account the differing nature and priority under the Bankruptcy Code of the various Claims anInterests. 28

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1 The table below summarizes the classification and treatment of the Claims and Interests undthe Plan. The Plan substantively consolidates the Debtors for voting and distribution purposes. 2 THE PROJECTED RECOVERIES SET FORTH IN THE TABLE BELOW AR3 ESTIMATES ONLY AND THEREFORE ARE SUBJECT TO CHANGE. FOR A COMPLETDESCRIPTION OF THE DEBTORS’ CLASSIFICATION AND TREATMENT OF CLAIM4 AND INTERESTS, REFERENCE SHOULD BE MADE TO THE ENTIRE PLAN. 5 Claim or Entitlement Projected Estimated Claims Proposed Treatment Class Interest to Vote Recovery Amount 6 Class 1 consists of Priority Non-Tax Claims. At the elec of the Liquidating Debtors, each Holder of a Priority Non- 7 Claim shall receive, in full satisfaction, settlement, release, Unimpaired; extinguishment of such Priority Non-Tax Claim, on or as sNot Entitled as practicable after the later of (i) the Effective Date, or 8 Priority Non- Approximately 1 to Vote 100% thirty (30) calendar days following the date on which sTax Claims $1,000,000.00 (Presumed to Priority Non-Tax Claim becomes an Allowed Priority N9 Accept) Tax Claim, (a) a Cash payment from the Liquidating Debequal to the Allowed amount of such Claim, or (b) such ot treatment as otherwise agreed by the Holder of such Claim 10 the Debtors or the Liquidating Debtors. Class 2 consists of any Miscellaneous Secured Clai Although all Miscellaneous Secured Claims have been pla 11 in one Class for the purposes of nomenclature, e Miscellaneous Secured Claim, to the extent secured by a 12 on any property or interest in property of any of the Debdifferent from that securing any other Miscellaneous Secu Claim, shall be treated as being in a separate sub-Class 13 purposes of voting and receiving distributions under the Pl Except to the extent that a Holder of an Allowed Miscellane 14 Secured Claim has been paid by the Debtors, in whole o part, prior to the Effective Date, on the later of (i) the EffecUnimpaired; Date and (ii) thirty (30) calendar days following the date 15 Miscellaneous Not Entitled Approximately which such Miscellaneous Secured Claim becomes an Allo2 Secured to Vote 100% $200,000.00 Miscellaneous Secured Claim, at the option of the LiquidaClaims (Presumed to Debtors, in full and final satisfaction of such Miscellane 16 Accept) Secured Claim, (i) each Allowed Miscellaneous Secured Cl shall be reinstated and Unimpaired in accordance with sec 17 1124 of the Bankruptcy Code, or (ii) each Holder of Allowed Miscellaneous Secured Claim shall receive, in satisfaction, settlement, and release of, and in exchange 18 such Miscellaneous Secured Claim, (x) payment in full in C of the unpaid portion of such Allowed Miscellaneous Secu 19 Claim, (y) the collateral securing such Allowed MiscellaneSecured Claim, or (z) such other treatment as may be agree by the Holder of such Claim and the Debtors or the Liquidat 20 Debtors. 21 22 23 24 25 26 27 28

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1 Class 3 consists of all General Unsecured Claims. Excep the extent that a Holder of an Allowed Class 3 Gen Unsecured Claim agrees to a less favorable treatment, 2 exchange for full and final satisfaction, settlement and relof the each Allowed Class 3 General Unsecured Claim, e 3 Holder of an Allowed Class 3 General Unsecured Claim s receive a Cash payment equal to its Pro Rata share of the Distributable Estate Assets on one or more dates as soo 4 reasonably practicable after (i) all General Unsecured Clahave been Allowed, Disallowed or otherwise resolved and the payment of (or reserves for) all Allowed Administra 5 Expenses, Allowed Priority Tax Claims, Allowed Prio Non-Tax Claims, Allowed Miscellaneous Secured Claims 6 Plan Expenses (unless the holder of the applicable claim agto other less favorable treatment); provided, however, in Approximately event that an aggregate of at least $1,000,000 in Cash in 7 General Impaired; Approx. $40,000,000 Distributable Assets is or will be distributed, as Distributi3 Unsecured Entitled to 0.0% - (excludes any PBGC under the Plan, to the Holders of Allowed Class 3 GenClaims Vote 5.0% 8 Unsecured Claims) Unsecured Claims on account of such Claims, any and all Distributable Assets in excess of such $1,000,000 C threshold shall be distributed by the Liquidating Debtors to9 Holders of Allowed Class 3 Claims and the PBGC (or ot Holder of the Class 4 Claims), on account of their Class 3 Class 4 Claims, respectively, on a Pro Rata basis as soo 10 reasonably practicable on the Class 3 Distribution Date provided further that in the discretion of the 11 Administrator, Allowed Class 3 General Unsecured Cla may receive Distributions before the reconciliation of Disputed Class 3 General Unsecured Claims provided 12 (x) reserves are maintained for any Class 3 General Unsec Claim that is Disputed at the time of such Distribution 13 (y) the Plan Administrator shall make a corrective Distribufollowing the resolution of any Disputed Claim within th (30) days of such resolution. 14 Class 4 consists of PBGC Unsecured Claims. The Holde the PBGC Unsecured Claims shall receive the treat provided for the PBGC on account of the PBGC Unsecu 15 Claims set forth in the PBGC Settlement. Specifica pursuant to the PBGC Settlement, the PBGC has agree PBGC Impaired; 16 TBD (approx. waive any right to receive Distributions under the Plan,4 Unsecured Entitled to <1% $145,000,000) account of the PBGC Unsecured Claims, unless and until Claims Vote Pro Rata Class 3 / Class 4 Distribution Trigger Event occur 17 is otherwise satisfied; upon the occurrence of the Pro Class 3 / Class 4 Distribution Trigger Event, the PBGC s 18 be entitled to share on a Pro Rata basis with the HolderAllowed Class 3 Claims any Excess Net Distributable Ass Impaired; Class 5 consists of all Interests. Holders of Interests s19 Not Entitled receive no distributions under the Plan, and on the Effec5 Interests to Vote 0% n/a Date, all Interests shall be deemed void and of no force (Deemed to effect. 20 Reject) 21 THE PLAN PROPONENTS BELIEVE THAT THE PLAN PROVIDES THE BES 22 RECOVERIES POSSIBLE FOR HOLDERS OF CLAIMS AGAINST THE DEBTORS AN23 THUS STRONGLY RECOMMEND THAT YOU VOTE TO ACCEPT THE PLAN. 24 C. Plan Voting Instructions and Procedures 25 1. Voting Rights 26 Under the Bankruptcy Code, acceptance of the Plan by a Class of Claims is determined bcalculating the number and the amount of Allowed Claims voting to accept, based on the actual tot27 Allowed Claims voting on the Plan. Acceptance by a Class of Claims requires more than one-half othe number of total voting Allowed Claims in the Class to vote in favor of the Plan and at least tw28

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1 Under the Bankruptcy Code, only Classes of Claims or Interests that are “Impaired” and thare not deemed as a matter of law to have rejected a plan under Section 1126 of the Bankruptcy Cod2 are entitled to vote to accept or reject the Plan. Any Class that is “Unimpaired” is not entitled to votto accept or reject the Plan and is conclusively presumed to have accepted the Plan. As set forth i3 Section 1124 of the Bankruptcy Code, a Class is “Impaired” if the legal, equitable, or contractual right4 attaching to the Claims or Interests of that Class are modified or altered. Any Class of Claims Interests that does not receive or retain any property under the Plan on account of such Claims 5 Interests is deemed to have rejected the Plan. 6 Pursuant to the Plan, Classes 3 and 4 (General Unsecured Claims and the PBGC, respectivelyare Impaired under the Plan and entitled to vote to accept or reject the Plan. Only the Holder of 7 Claim as of [DATE]May 12, 2021 (the “Voting Record Date”), may vote to accept or reject the Pla8 Pursuant to the Plan, Claims in Classes 1 and 2 are Unimpaired by the Plan, and such Holder9 are conclusively presumed to have accepted the Plan and are therefore not entitled to vote on the Pla10 Pursuant to the Plan, Interests in Class 5 will not receive or retain any property under the Plaon account of such Interests, as applicable, and are, therefore, deemed to reject the Plan and are n11 entitled to vote on the Plan. 12 2. Solicitation Materials 13 The Debtors have engaged Donlin, Recano & Company, Inc. (the “Voting Agent”) to serve a14 the voting agent to process and tabulate Ballots for each Class entitled to vote on the Plan and tgenerally oversee the voting process. The following materials shall constitute the solicitation packag15 (the “Solicitation Package”): 16 • This Disclosure Statement, including the Plan and all other Exhibits annexed thereto; 17 • The Bankruptcy Court order approving this Disclosure Statement (the “Disclosure StatemeOrder”); 18 • The notice of, among other things, (i) the date, time, and place of the hearing to consid19 Confirmation of the Plan and related matters and (ii) the deadline for filing objections t20 Confirmation of the Plan (the “Confirmation Hearing Notice”); 21 • One or more Ballots, as applicable, to be used in voting to accept or to reject the Plan, anapplicable voting instructions (the “Voting Instructions”); 22 • A pre-addressed return envelope; and 23 • Such other materials as the Bankruptcy Court may direct or approve. 24 The Plan Proponents, through the Voting Agent, will distribute the Solicitation Package in 25 accordance with the Disclosure Statement Order. The Solicitation Package is also available at the Debtors’ restructuring website at https://www.donlinrecano.com/Clients/fc/Index. 26 . 27 Prior to the Confirmation Hearing, the Plan Proponents may file a Plan Supplement that includes, 28

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1 regarding the Plan Administrator; and (ii) any executory contracts and unexpired leases designated for assumption by the Debtors. As the Plan Supplement is updated or otherwise modified, such 2 modified or updated documents will be made available on the Debtors’ restructuring website at https://www.donlinrecano.com/Clients/fc/Index. 3 If you are the Holder of a Claim and believe that you are entitled to vote on the Plan, but yo4 did not receive a Ballot or your Ballot is damaged or illegible, or if you have any questions concerninvoting procedures, you should contact the Voting Agent by writing to Donlin, Recano & Compan5 Inc. Re: Freedom Communications, Inc., et al. Attn: Voting Department; PO Box 19904Blythebourne Station; Brooklyn, NY 11219; Email: [DRCVote@DonlinRecano.com]. If the reaso6 that you did not receive a Ballot is because your Claim is subject to a pending claim objection and yo7 wish to vote on the Plan, you must file a motion pursuant to Bankruptcy Rule 3018 with thBankruptcy Court for the temporary allowance of your Claim for voting purposes so that it is hear8 by the Bankruptcy Court on or before July 7, 2021by [DATE], 2021, or you will not be entitled to votto accept or reject the Plan. 9 THE DEBTORS AND THE LIQUIDATING DEBTORS, AS APPLICABLE, RESERV10 THE RIGHT THROUGH THE CLAIM OBJECTION PROCESS TO OBJECT TO AN11 CLAIM. 12 3. Voting Instructions and Procedures 13 All votes to accept or reject the Plan must be cast by using the Ballots enclosed with thSolicitation Packages. No votes other than ones using such Ballots will be counted, except to th14 extent the Bankruptcy Court orders otherwise. The Bankruptcy Court has fixed [DATE], 2021 asMa12, 2021 is the Voting Record Date for the determination of the Holders of Claims who are entitled t15 (i) receive a Solicitation Package and (ii) vote to accept or reject the Plan. The Voting Record Dat16 and all of the Plan Proponents’ solicitation and voting procedures shall apply to all of the DebtorCreditors and other parties in interest. 17 If you are a Holder of a Claim in a Class that is entitled to vote, after carefully reviewing th18 Plan, this Disclosure Statement, and the detailed instructions accompanying your Ballot, you are asketo indicate your acceptance or rejection of the Plan by voting in favor of or against the Plan on th19 accompanying Ballot. 20 The deadline to vote on the Plan is [DATE]June 9, 2021 at 5:00 p.m. (prevailing Pacifi21 Time) (the “Voting Deadline”). 22 In order for your vote to be counted, your Ballot must be properly completed, in accordancwith the Voting Instructions on the Ballot, and received no later than the Voting Deadline at th23 following address, if by First-Class Mail: 24 Freedom Communications, Inc. Ballot Processing c/o Donlin, Recano & Company, Inc. 25 Attn: Voting Department 26 P.O. Box 199043 192016 Blythebourne Station Brooklyn, NY 11219 27 Ballots sent by hand delivery or overnight mail should be sent to the following address: 28

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1 Freedom Communications, Inc. Ballot Processing c/o Donlin, Recano & Company, Inc. 2 Attn: Voting Department 6201 15th Avenue 3 Brooklyn, NY 11219 4 Holders of Claims in Class 3 (General Unsecured Claims) and Class 4 (PBGC Unsecure5 Claims) as of the Voting Record Date are entitled to vote to accept or reject the Plan, and they may dso by completing the appropriate Ballots and returning them in the envelope provided to the Votin6 Agent so as to be actually received by the Voting Agent by the Voting Deadline. Each Holder of Claim must vote its entire Claim within a particular Class either to accept or reject the Plan and ma7 not split such votes. If multiple Ballots are received from the same Holder with respect to the samClaim prior to the Voting Deadline, the last timely received, properly executed Ballot will be deeme8 to reflect that voter’s intent and will supersede and revoke any Ballot previously received. The Ballot9 will clearly indicate the appropriate return address. It is important to follow the specific instructionprovided on each Ballot. 10 Unless otherwise provided in the Voting Instructions accompanying the Ballots, the followin11 Ballots will not be counted in determining whether the Plan has been accepted or rejected: 12 • Any Ballot that fails to clearly indicate an acceptance or rejection, or that indicates both a13 acceptance and a rejection of the Plan; 14 • Any Ballot received after the Voting Deadline, except if the Debtors have granted an extensioof the Voting Deadline with respect to such Ballot or by order of the Bankruptcy Court; 15 • Any Ballot containing a vote that the Bankruptcy Court determines was not solicited 16 procured in good faith or in accordance with the applicable provisions of the Bankruptcy Cod17 • Any Ballot that is illegible or contains insufficient information to permit the identification othe Claim Holder; 18 19 • Any Ballot cast by a Person or Entity that does not hold a Claim in the voting Class with respeto which the Ballot is cast; and 20 • Any Ballot without an original signature. 21 Any party who has previously submitted to the Voting Agent prior to the Voting Deadline 22 properly completed Ballot may revoke such Ballot and change its vote by submitting to the VotinAgent prior to the Voting Deadline a subsequent properly completed Ballot for acceptance or rejectio23 of the Plan. If more than one timely, properly completed Ballot is received, only the last timel24 received Ballot will be counted for purposes of determining whether the requisite acceptances havbeen received. Any party who has delivered a properly completed Ballot for the acceptance o25 rejection of the Plan that wishes to withdraw such acceptance or rejection rather than changing its votmay withdraw such acceptance or rejection by delivering a written notice of withdrawal to the Votin26 Agent at any time prior to the Voting Deadline. To be valid, a notice of withdrawal must (i) contaithe description of the Claims to which it relates and the aggregate principal amount represented b27 such Claims, (ii) contain the original signature of the withdrawing party, (iii) contain a certificatio28

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1 that the withdrawing party owns the Claims and possesses the right to withdraw the vote sought to bwithdrawn, and (iv) be actually received by the Voting Agent prior to the Voting Deadline. 2 ALL BALLOTS ARE ACCOMPANIED BY VOTING INSTRUCTIONS. IT I3 IMPORTANT THAT THE HOLDER OF A CLAIM IN THE CLASSES ENTITLED TO VOTFOLLOW THE SPECIFIC INSTRUCTIONS PROVIDED WITH EACH BALLOT. 4 5 In addition, for all Holders of Class 3 Claims (General Unsecured Claims) and Class 4 (PBGUnsecured Claims), the Ballot contains an option to “opt-out” of certain releases provided under th6 Plan. The Plan provides that each Holder of a Claim that votes to accept, or is deemed to accept, thPlan is considered a “Releasing Creditor” under the Plan and is bound by certain releases provided i7 Article IX thereof, and as set forth below, other than any Holder of a Class 3 Claim or a Class 4 Claithat affirmatively elects on its Ballot to opt out of being a Releasing Creditor. Each Class 3 and Clas8 4 Ballot will contain the text of the proposed release and instructions to each Holder of a Class 3 or 9 Class 4 Claim regarding the option to opt-out of the release. 10 If you have any questions about (i) the procedure for voting your Claim, (ii) the SolicitatioPackage that you have received, or (iii) the amount of your Claim, or if you wish to obtain, at yo11 own expense (unless otherwise specifically required by Bankruptcy Rule 3017(d)), an additional copof the Plan, this Disclosure Statement, or any appendices or Exhibits to such documents, please conta12 the Voting Agent by writing to Donlin, Recano & Company, Inc. Re: Freedom Communications, Inc13 et al., Attn: Voting Department; PO Box 199043, Blythebourne Station; Brooklyn, NY 11219. Copieof the Plan, Disclosure Statement, Plan Supplement and other documents filed in these Chapter 114 Cases may be obtained free of charge on the Voting Agent’s website https://www.donlinrecano.com/Clients/fc/Index. Documents filed in these Chapter 11 Cases may als15 be examined between the hours of 9:00 a.m. and 4:00 p.m., prevailing Pacific Time, Monday througFriday (excluding federal holidays), at the Office of the Clerk of the Bankruptcy Court, 411 We16 Fourth St., Santa Ana, California. 17 The Voting Agent will process and tabulate Ballots for the Classes entitled to vote to accept o18 reject the Plan and will file a voting report (the “Voting Report”) in accordance with the DisclosurStatement Order. The Voting Report will, among other things, describe every Ballot that does n19 conform to the Voting Instructions or that contains any form of irregularity, including, but not limiteto, those Ballots that are late, illegible (in whole or in material part), unidentifiable, lacking signature20 lacking necessary information, or damaged. 21 THE PLAN PROPONENTS URGE HOLDERS OF CLAIMS WHO ARE ENTITLE 22 TO VOTE TO TIMELY RETURN THEIR BALLOTS AND TO VOTE TO ACCEPT THPLAN BY THE VOTING DEADLINE. 23 4. Confirmation Hearing and Deadline for Objections to Confirmation 24 Section 1128(a) of the Bankruptcy Code requires the Bankruptcy Court, after notice, to hold 25 hearing on Confirmation of the Plan. Section 1128(b) of the Bankruptcy Code provides that any partin interest may object to Confirmation of the Plan. 26 27 The Bankruptcy Court has scheduled the Confirmation Hearing to commence on Jul7[DATE], 2021 at 2:00 p.m.[TIME] (prevailing Pacific Time), before the Honorable Mark S. Wallac28 United States Bankruptcy Judge, in the United States Bankruptcy Court for the Central District o

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1 California, 411 West Fourth St., Courtroom 6C, Santa Ana, California 92701. The ConfirmatioHearing Notice, which sets forth the time and date of the Confirmation Hearing, has been include2 along with this Disclosure Statement. The Confirmation Hearing may be adjourned from time to timby the Bankruptcy Court without further notice, except for an announcement of the adjourned dat3 made in the agenda for the Confirmation Hearing or at the Confirmation Hearing or any adjournme4 thereof. 5 Objections to Confirmation of the Plan must be filed and served on the Plan Proponents ancertain other entities, all in accordance with the Confirmation Hearing Notice, so that they are actuall6 received by no later than June 9[DATE], 2021 at 5:00 p.m,[TIME] (prevailing Pacific Time). Unlesobjections to Confirmation of the Plan are timely served and filed in compliance with the Disclosur7 Statement Order, which is attached to this Disclosure Statement, they may not be considered by thBankruptcy Court. 8 9 III. GENERAL INFORMATION ABOUT THE DEBTORS AND THE CASES 10 A. Business Overview and Background 11 Prior to the Petition Date, the Debtors, headquartered in Santa Ana, California, wercollectively a privately owned information and entertainment company consisting of print publication12 and interactive businesses. The Debtors’ portfolio included daily and weekly newspapers, magazine13 and other specialty publications. The Orange County Register (the “OC Register”) was the Debtorsflagship newspaper. In addition, the Debtors operated an interactive business, which offered websit14 complements, as well as digital and mobile products, to their print publications. The Debtors also hatwo real property holdings, which were held in SPV II (the Santa Ana Property (defined below) an15 SPV VI (the Riverside Property (defined below). 16 Founded in 1935 by R.C. Hoiles, the Debtors’ enterprise was operated as a family-owne17 business until 2004, when private equity firms, The Blackstone Group and Providence Equity PartnerInc. and certain affiliates, acquired an approximate 40% share in the company for approximately $4618 million (which share thereafter increased to approximately 48%), with the remaining shares being helby the Hoiles family. On September 1, 2009, the company filed chapter 11 bankruptcy cases in th19 United States Bankruptcy Court for the District of Delaware, and exited bankruptcy in April 2010. 20 Thereafter, in 2012, the company sold its entire broadcast television division to a third part21 leaving the company essentially free of debt. Commencing in 2012, the company began selling thmajority of its newspaper portfolio. In July 2012, Freedom Communications Holdings, Inc. (“FCHI”22 completed a merger with 2100 Trust, LLC ("2100 Trust"), an entity established by investor AaroKushner, and 2100 Freedom Inc. At the effective time of the merger, 2100 Freedom Inc. was merge23 into FCHI, with FCHI surviving the merger. All outstanding shares of FCHI were cancelled and thoutstanding shares of 2100 Freedom Inc. became the new outstanding shares of FCHI, with FCH24 becoming a wholly-owned subsidiary of 2011 Trust. After the merger, 2100 Trust changed its nam25 to 2100 Freedom, Inc. This transaction marked the final transaction by the company following itemergence from bankruptcy in 2010 and subsequent divestitures of all of its remaining business unit26 Following the merger, the Debtors continued to operate under the umbrella name “FreedoCommunications.” As of the close of the transaction in July 2012, the Debtors’ businesses consiste27 of its flagship newspaper, the OC Register, and a community newspaper portfolio. 28

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1 With a new focus on the OC Register and related newspaper portfolio, commencing in the laquarter of 2012, the Debtors began a period of expansion and redirection, including increasin2 newsroom and sales staffing, increasing customer realization and retention programs, acquirinmagazine publications and launching new daily publications and expanding coverage to new sector3 including business, arts, academia, politics, fashion, philanthropy, faith, family, home, transportatio4 and food. Since 2012, the Debtors took the OC Register from being the 20th largest newspaper in thUnited States to being the 8th largest as measured by circulation, and sought to strategically sell an5 acquire certain assets to allow the Debtors to focus their efforts on strengthening their core businesand managing cost efficiency. 6 Starting at the end of 2012 and continuing through 2014, the Debtors began to sell certain o7 their smaller community newspapers. The Debtors also sold real property holdings in Colorado an8 Irvine and Victorville, California. As part of its targeted growth strategy, in November 2013, thDebtors acquired substantially all of the assets of the Press Enterprise newspaper group, including Th9 Press-Enterprise and La Prensa (which later became Unidos, a Spanish language newspaper). 10 B. Circumstances Leading to Chapter 11 Filing 11 The Debtors’ bankruptcy filing was attributable to various factors including falling advertisin12 revenue, competition from internet-based advertising, and volatility in newsprint prices. In an effoto mitigate declining revenue, prepetition, the Debtors had made cost reductions by consolidatin13 operational functions, introducing new business models and outsourcing distribution, printing ancustomer care operations. However, despite the Debtors’ best efforts to increase revenues an14 decrease expenses, the Debtors were unable fully achieve their financial goals to such a degree thwould enable them to continue to operate under their current capital structure. Accordingly, th15 Debtors made the decision to sell all of their assets and operations for the benefit of all parties throug16 the chapter 11 process. On November 1 and 2, 2015, the Debtors filed chapter 11 petitions for reliin the United States Bankruptcy Court, Central District of California (Santa Ana Division). 17 C. Prepetition Secured Debt 18 19 As of the Petition Date, the Debtors had approximately $51.2 million of allegedly secured deasserted by certain entities, including the Prepetition Loan Parties (defined and discussed below) i20 the amount of approximately $19.46 million, and the PBGC in the amount of approximately $15.4million. As of the Petition Date, substantially all of the Debtors' assets were pledged to secure thei21 obligations to creditors. 22 Specifically, certain Debtors, as borrowers or guarantors, were parties to a 2013 CredGuaranty Agreement (as amended, together with related agreements and documents, the “Prepetitio23 Credit Documents”) with Silver Point, as administrative agent and collateral agent, and certain lender24 (collectively, the “Prepetition Loan Parties”). As of the Petition Dates, the Prepetition Loan Partieasserted secured claims against the Debtors in the principal sum of not less than $12 million, plu25 accrued interest, charges, fees, expenses, and a “make-whole amount” of more than $5.2 million. ThDebtors, the Committee and the Prepetition Loan Parties resolved all disputes relating to th26 Prepetition Loan Parties’ secured claims, which were paid in full by the Debtors after the closing the Sale (discussed below). 27 28 D. PBGC Claims

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1 The PBGC, on behalf of The Retirement Plan of Freedom Communications, Inc. (the “PensioPlan”), filed with the California Secretary of State notices of federal lien under I.R.C. sec. 412(n2 and/or sec. 430(k), to secure obligations owed by the Debtors to the PBGC based on missed PensioPlan contributions (including interest thereon) totaling more than $15.4 million. In addition, the PBG3 now holds an approximately $145 million general unsecured Class 4 claim arising out of th4 underfunding of the Pension Plan. 5 IV. THE CHAPTER 11 CASES 6 A. First Day Orders 7 On November 5, 2015, upon the Debtors’ motions, the Bankruptcy Court granted certain “fir8 day” relief to the Debtors pursuant to which the Debtors were authorized to continue to operate thebusinesses notwithstanding the pendency of the Chapter 11 Cases, including orders authorizing th9 Debtors to pay and honor certain prepetition employee related obligations, maintaining their existincash management systems, and granting certain other standard administrative relief. [Docket Nos. 410 47]. 11 B. Cash Collateral / DIP Financing 12 Recognizing the need to access cash, the Debtors and their advisors engaged in discussion13 with the Debtors’ primary secured creditor asserting an interest in the Debtors' cash collateral – SilvePoint, as prepetition agent of the Prepetition Loan Parties – regarding the terms of the Debtors14 consensual continued use of cash collateral. In addition, the Debtors engaged in discussions witSilver Point (as well as other potential financing sources) regarding the terms of debtor-in-possessio15 (DIP) financing to allow the Debtors to operate pending the contemplated sale of their businesses. A16 a result of such negotiations, the Debtors sought and obtained from the Court interim and final order[Docket Nos. 47 & 239] authorizing (as applicable) postpetition financing consisting of a senio17 secured term loan credit facility in the aggregate principal amount not to exceed $4.5 million, plus thamount necessary to consummate a refinancing of the Prepetition Loan Parties’ secured claims. Th18 Court’s orders granted, in part, first priority liens, in addition to superpriority claims, in favor of SilvPoint, the DIP agent, for the benefit of the DIP lenders on all prepetition and postpetition property 19 the Debtors’ Estates and all proceeds thereof, excluding a lien on avoidance actions and avoidanc20 claim proceeds. As a result of negotiations among the Committee, the Debtors, the DIP lenders anprepetition secured creditors, the originally proposed DIP facility was modified in a number of respect21 (as reflected in the final order), including an increase in the amount of new money available under thDIP facility from $3 million to $4.5 million to allow for the cases to be able to operate through th22 contemplated end of the sale process in March 2016 without going cash negative, and the eliminatio23 of any proposed liens for Silverpoint or the PBGC on the Estates’ avoidance actions. During thpendency of the Chapter 11 Cases, prior to the filing of the Plan, the DIP lenders’ claims were paid o24 otherwise satisfied in full by the Debtors, including payment with cash proceeds from the Sale (defineand discussed below). 25 C. Payment of Prepetition Commission Obligations 26 27 The Debtors sought on an emergency basis an order authorizing the payment of prepetitiocommission obligations for five employees exceeding the statutory cap of (then) $12,475 for eac28 employee under Bankruptcy Code section 507(a)(4). In their motion, the Debtors explained that the

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1 had recently lost an important sales representative to a competitor, and that they needed to ensure ththe affected employees felt confident that their compensation would not be impacted by the bankruptc2 filings. Subsequent to the filing of the motion, the Debtors withdrew their request to pay one employehis commission based on issues raised by the U.S. Trustee. The Court entered orders [Docket No3 219 & 277] authorizing the payment of prepetition commission obligations to the other fou4 employees, which exceeded the statutory cap amounts by approximately $120,000 in the aggregate. 5 D. Debtors’ Customer, Subscriber and Advertiser Programs 6 In a “first day” motion [Docket No. 14], the Debtors requested and subsequently receiveauthority (subject to certain modifications) to honor their prepetition obligations under their custome7 related programs and practices (designed to develop and sustain the Debtors’ positive reputations i8 the marketplace) to customers, subscribers, and advertisers in the ordinary course of business afollows [Docket Nos. 42 & 240]: 9 Authorized (estimated prepetition 10 Program/Obligation amounts unless otherwise noted) Refunds $565,683 11 Delivery Providers $790,000 (maximum cap; subject to 12 Committee consent) Prepaid Subscriptions $5,521,000 13 Prepaid Advertising $1,933,000 Postage Obligations $11,500 14 Advertising Infrastructure & Brokered $1,247,000 (maximum cap; subject 15 Ads to Committee consent) Community Partners Commissions $236,000 16 Credit Card Fees $65,000 Customer Service Providers $112,000 17 QChief Customer Service Provider $3,000 18 Outside Contractors $49,000 Staffing Companies $500,000 (maximum cap; subject to 19 Committee consent) 20 Totals $11,033,183.00 21 E. The Sale of Substantially All of the Debtors’ Assets 22 Following a review of strategic alternatives for their businesses, the Debtors, in consultatio23 with their advisors, determined that maximizing the value of their estates would be best accomplishe24 through an orderly sale, free and clear of liabilities, of substantially all of their assets, comprisemainly of the Debtors’ print publications, interactive businesses, real property holdings, account25 receivable, and contracts and leases. Upon the Debtors’ motion filed in January 2016, the Couapproved certain bidding, auction and sale procedures pursuant to an order entered on February 26 2016 [Docket No. 371]. 27 Prior to and following the entry of the bidding procedures order, the Debtors – with the activ28 involvement of their advisors (including GlassRatner, Mosier & Co., Inc. and FTI Consulting) and th

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1 ongoing input of the Committee and the PBGC – continued to market the Debtors’ assets to potentibuyers. Among other efforts, FTI reached out to over 250 parties that FTI and the Debtors believe2 would be interested in purchasing either the business assets and/or the real estate holdings of thDebtors, and negotiating nondisclosure agreements with 35 interested parties. Subsequently, two day3 prior to the bid deadline, in March 2016, the Debtors reached a stalking horse agreement wit4 MediaNews Group, Inc. d/b/a Digital First Media (“DFM”), providing for a purchase price of $45. million, less an estimated $2.2 million for net adjustments for purchased cash, escrow for cure cost5 and contingent consideration based on collected accounts receivable. Two qualified overbids werreceived, including one by Orange County Media, LLC, (“OCM”) a subsidiary of Tribune Publishin6 Co. (“Tribune”), and an auction was held on March 16, 2016. At the conclusion of the auction, whicincluded five rounds of bidding, OCM was selected by the Debtors as the successful bidder, and DF7 was selected as the backup bidder. It became known prior to the auction that the Department of Justic8 (the “DOJ”) was considering seeking to enjoin the Tribune’s ability to consummate the saltransaction, but the Debtors believed that they had negotiated with the Tribune to mitigate the ris9 associated with the Tribune being enjoined from consummating the sale. However, when attemptinto work through the revisions to the Tribune’s purchase agreement immediately following the auctio10 it became clear that the Tribune was unwilling to provide to the Debtors the protections that thDebtors and consultation parties believe they had received during the auction process. 11 12 On March 17, 2016, the parties learned that the DOJ had commenced an action against thTribune seeking to enjoin the Tribune from consummating the sale (the “DOJ Action”). Given th13 risks associated the DOJ’s efforts to enjoin the Tribune, and the Tribune’s desire to push that risentirely onto the Debtors, the Debtors, following consultation with the Committee and oth14 consultation parties, determined that the Tribune’s bid was no longer the highest and best biConsequently, the Debtors selected DFM as the successful bidder. As set forth in the DFM purchas15 agreement, as amended, the “Base Purchase Price” for substantially all of the Debtors’ assets wa16 $49,800,000 in cash. The Court entered an order on March 30, 2016 [Docket No. 562] approving thsale of substantially all of the Debtors’ assets to DFM (the “Sale”). The Sale subsequently close17 with the net cash proceeds remitted to the Debtors. 18 F. The Silver Point Settlement 19 The Debtors, the Committee and Silver Point Finance, as the DIP agent for the DIP Lender20 and as the prepetition agent for the Prepetition Loan Parties, entered into a settlement in March 201pursuant to which the claims and defenses asserted by the Committee with respect to the DIP Lenders21 claims and the Prepetition Loan Parties’ claims were resolved. Under the settlement, among othprovisions, (i) the Estates would receive $1.5 million in cash proceeds obtained from the Sale 22 substantially all of the Debtors’ assets that would otherwise be recoverable by the DIP Lenders; (ii23 the DIP Lenders’ secured claims would be reduced by $2.5 million; and (iii) the Committee woulstipulate to be bound by the stipulations and admissions contained in the DIP Order and stipulate th24 the Committee’s challenge period expired and all potential challenges to the DIP Lenders’ anPrepetition Loan Parties’ respective claims and liens (including the Committee’s assertions that th25 “make-whole amounts” were unenforceable under state law) were released. This settlement waapproved by the Court pursuant to an order entered on March 23, 2016 [Docket No. 539]. After th26 closing of the Sale, the DIP Claims and the Prepetition Loan Parties’ claims were paid in full o27 otherwise satisfied by the Debtors. 28 G. The Committee Action

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1 (1) Commencement and Prosecution of the Committee Action 2 On August 31, 2016, the Debtors and the Committee entered into a stipulation [Docket N3 858] (the “Standing Stipulation”) whereby the Debtors granted the Committee “exclusive leav4 standing, and authority to commence, prosecute, and settle any Insider Estate Causes of Action witfull rights and privileges and in the stead of the Debtors, with any and all recoveries to be for th5 benefit of” the Estates. The Bankruptcy Court approved the Standing Stipulation on September 2016 [Docket No. 861]. 6 Pursuant to the Standing Stipulation, in January 2017, the Committee commenced in th7 Bankruptcy Court Adversary Proceeding 8:17-ap-01012 (the “Committee Action”) against Aaro8 Kushner (the Debtors’ former CEO), Eric Spitz (the Debtors’ former President), Larry Chin(principal of Financial Institution Consulting Corp. (“FICC”)), and certain other defendants. As s9 forth in the Committee’s complaint, the Committee asserted on behalf of the Debtors (among oththings) a breach of fiduciary duty claim against Kushner and Spitz, and an aiding and abetting breac10 of fiduciary duty claim against Chinn, FICC and certain other defendants. The Committee allegethat Kushner and Spitz’s investment decisions on behalf of the Pension Plan directly impacted th11 adverse funding status of the Pension Plan, and thus determined (among other things) the Debtor12 contribution obligations to the Pension Plan and, ultimately, the Debtors’ liability to PBGC and othcreditors. Effective as of March 31, 2016, the Pension Plan was terminated by agreement and PBG13 became the statutory trustee of the Pension Plan. More specifically, the Committee alleged thKushner and Spitz negligently invested the Pension Plan’s assets in a life insurance program designe14 and promoted by Chinn, FICC and other defendants. Prior to the related settlements discussed belothe Committee Action materially progressed, including the parties participating in a mediatio15 document productions having been undertaken, and numerous depositions having been conducted. A16 explained below, the applicable parties reached settlements with defendants Kushner, Spitz and Chinand the PBGC, thereby providing the Estates ultimately with millions of dollars in cash (to pa17 Administrative Expenses and fund a Chapter 11 plan) and resolving the Estates’ and Committee’claims in the Committee Action other than their claims against defendant Richard Covelli and hi18 related entities, which were assigned to the PBGC pursuant to the PBGC Settlement. 19 (2) The Chinn Settlement 20 The Committee, on behalf of the Debtors, Larry Chin (a defendant in the Committee Action21 Financial Institution Consulting Corp. (“FICC”) (Mr. Chinn’s related entity), the PBGC, and certaiother parties entered into a settlement in June 2018, pursuant to which the parties resolved the claim22 asserted by the Committee and the PBGC against Chinn and FICC in the Committee Action. A tot23 settlement payment of $400,000 would be paid to the Committee and PBGC, funded by AAI(Chinn’s insurance company) under a “burning” policy (a policy that is depleted dollar for dollar fo24 costs of defense). Absent the settlement, continued litigation would further deplete the coveragavailable under the AAIC policy as well as increase the expense to the Debtors’ estates. Under th25 settlement, Chinn and FICC also agreed to cooperate with the Committee and PBGC in the prosecutioof their respective claims against the remaining defendants by, among other things, producing releva26 documents and voluntarily sitting for interviews. The Bankruptcy Court approved this settleme27 pursuant to an order entered on August 1, 2018 [Docket No. 1517]. 28 (3) The Kushner/Spitz Settlement

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1 The Committee, Aaron Kushner and Eric Spitz (defendants in the Committee Action), and th2 PBGC entered into a settlement in August 2019, pursuant to which the parties resolved the breach ofiduciary duty and other claims asserted by the Committee against Kushner and Spitz in the Committe3 Action, and ERISA claims related to investments made by the Pension Plan asserted by the PBG4 against Kushner and Spitz. 5 The settlement provided for a $7,835,000 settlement payment to the Committee and PBG(the “Kushner/Spitz Settlement Payment”), funded by the settling defendants’ professional liabilit6 insurers with the remaining amount of coverage available under two “burning” policies (policies thhave been or would be (absent settlement) depleted dollar-for-dollar for costs of defense). Th7 Committee and PBGC determined, based on financial disclosures provided by Kushner and Spitz, th8 the amount of insurance coverage available for a settlement with the settling defendants, withofurther litigation, exceeds any amount that either the Committee or PBGC could collect from th9 settling defendants after trial. The settlement payment would be deposited in Committee counsel’trust account, pending a separate allocation agreement to be entered into between the Committee an10 PBGC. The parties’ settlement would preserve the most likely source of any recovery against Kushneand Spitz (the remaining amount of insurance coverage), while at the same time allowing the Debtors11 estates to avoid any additional expense, delay or uncertainty related to further litigation with Kushn12 and Spitz and/or efforts to collect on any judgments entered in favor of the Committee after trial. ThBankruptcy Court approved the settlement pursuant to an order entered on September 25, 20113 [Docket No. 1584]. 14 (4) The PBGC Settlement 15 The Committee and the PBGC entered into a settlement (the “PBGC Settlement”) in Novembe16 2019 relating to, among other matters, the division of the Kushner/Spitz Settlement Payment and othrecoveries between the Estates and the PBGC. The PBGC Settlement is a “best of both worlds17 solution for the Debtors and the Estates and their creditors, including the PBGC and the Debtors’ otheunsecured creditors. The PBGC Settlement would be funded with the $8,235,000 of proceeds receive18 or to be received in connection with the settlement agreements executed to date in the CommitteAction and other judicial proceedings by the PBGC (including the Kushner/Spitz Settleme19 Payment), with one-third ($2,745,000) to be paid to the PBGC, one-third ($2,745,000) to be paid t20 the Estates as consideration for the legal services provided by Committee counsel in connection witthe Committee Action, and the remaining one-third ($2,745,000) to be paid to the Estates. Thus, th21 PBGC Settlement resulted in a total payment of $5,490,000 to the Estates. 22 As part of the PBGC Settlement, the Committee assigned the claims asserted in the Committe23 Action against defendant Richard Covelli and his related entities to the PBGC, which will now haexclusive authority to prosecute and/or settle said claims, and any funds recovered by the PBGC o24 account of said claims belong exclusively to the PBGC. The Estates will avoid incurring furthlitigation expense in connection with the Committee Action (the Committee has entered int25 settlement agreements with all other defendants in the Committee Action), and the PBGC, which hathe resources available to pursue the litigation against Covelli to a final judgment (if necessary), wi26 be able to continue to seek redress for the harm suffered by the Debtors and their Pension Plan as 27 result of Covelli’s alleged misconduct. Further, the PBGC agreed to waive any right to receive furthedistributions from the Debtors unless and until (i) all administrative and priority claims are paid i28 full, and (ii) a distribution of $1,000,000 is made to the Debtors’ other general unsecured creditors. I

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1 the event that both of those conditions are satisfied, the PBGC would then be entitled to share ratablin any additional distributions (i.e., distributions over and above the $1,000,000 distribution reference2 above) made to general unsecured creditors. Because the PBGC is the largest unsecured creditor othe Debtors, with in excess of $174,000,000 of unpaid claims filed in the Chapter 11 Cases, this aspe3 of the PBGC Settlement dramatically increases the likelihood that the Debtors’ other unsecure4 creditors will receive distributions from the Estates. Moreover, on February 6, 2020, Covelli filed chapter 7 case before the United States Bankruptcy Court for the Western District of North Carolin5 The PBGC’s action against Covelli has been stayed pending the outcome of Covelli’s chapter 7 cas 6 As explained by the Committee in its motion for approval of this settlement, the PBGSettlement provides for a total payment of $5,490,000 to the Estates, of which $2,745,000 will b7 compensation to the Estates for the three years of hard-fought litigation and resulting expense incurre8 by Committee counsel in connection with its investigation and prosecution of the Committee ActioThe aggregate $5,490,000 payment will facilitate the Debtors in continuing to administer the Chapt9 11 Cases and confirming a Chapter 11 plan for the benefit of the Estates and their creditors. ThBankruptcy Court entered an order approving the PBGC Settlement pursuant to an order entered o10 January 13, 2020 [Docket No. 1609]. 11 H. Claim Bar Dates 12 The Debtors filed a motion and obtained an order [Docket No. 355] setting the following cas13 bar dates: 14 General Bar Date for proofs of claim: April 1, 2016. Governmental Bar Date: The later of the (i) general bar date or (ii) April 29, 2016 for clai15 against Debtors who file petitions on November 1, 2015 and April 30, 2016 for claims who file16 petitions on November 2, 2016. Rejection Bar Date: The later of (i) the general bar date or (ii) 30 days after the date of entr17 of an order authorizing the rejection of such contract or lease or any automatic rejection of suc18 contract or lease. Avoidance Bar Date: The later of the (i) the general bar date or (ii) 30 days after the entry o19 a judgment avoiding the transfer. 20 Supplemental Bar Date: In the event the Debtors amend their schedules, the supplemental bdate is the later of the (i) general bar date or (ii) 30 days after the Debtors provide notice to the holde21 of the amendment. 22 I. Incentive and Severance Programs 23 The Debtors filed a motion seeking approval of an employee incentive program for ke24 members of the Debtors’ management (the “KEIP”) based on obtaining certain value thresholds iconnection with the sale of substantially all of the Debtors’ assets, and an employee severance progra25 (the “ESP”) providing for payment of severance pay to associate employees and key executive(including one insider executive) of the Debtors in the event of a termination of employment pos26 January 1, 2016. 27 Specifically, under the KEIP, the key seven executives received payouts from a bonus po28 between $500,000 and $1,500,000 (maximum) only upon the conclusion of a qualifying sale resultin

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1 in an aggregate value to the Debtors’ estates of at least $42 million (the “KEIP Payment Event”(which condition was satisfied upon the Sale described above). Under the ESP, the associat2 employees were provided with two weeks of severance in the case of a termination of employmepost-January, 2016. Based upon the current salary amounts, the payments for individual associat3 employees ranged from $400 to $6,632 (based upon on two weeks of pay). For the seven ke4 executives eligible for the ESP, the maximum payout was approximately $51,000 (based on two weekof pay), with a mean payout of approximately $7,300. The Court approved the KEIP and the ES5 pursuant to an order entered on March 2, 2016 [Docket No. 441]. 6 J. Extension of Exclusivity Periods for Filing a Chapter Plan and for Soliciting Acceptances to the Plan 7 8 The Debtors, and later with the Committee, filed multiple motions and received orderextending the Debtors’ exclusivity deadlines for filing a plan and for soliciting acceptances thereof t9 most recently, August 26, 2017 and October 25, 2017, respectively. The Debtors’ plan filing ansolicitation exclusivity have now expired. No other plans, as alternatives to the Debtors’ an10 Committee’s proposed Plan, have been filed. 11 K. Retention of Debtors’ Professionals 12 The Debtors employed (i) initially Lobel Weiland Golden Friedman LLP (“LWGF”) a13 bankruptcy counsel [Docket No. 238] and subsequently Shulman Hodges & Bastian LLP (“SHB”)3 abankruptcy counsel effective as of March 1, 2018 [Docket No. 1499]4; (ii) GlassRatner Advisory 14 Capital Group LLC (“GlassRatner”) as financial advisors, with Brad Smith, Senior Managing Directof GlassRatner, serving as the Debtors’ Chief Restructuring Officer as of April 1, 2016 [Docket No15 262 & 618]; (iii) Rutan & Tucker, LLP as special corporate counsel [Docket No. 254]; (iv) Mosier 16 Co., Inc. as the Debtors’ independent sale representative in all aspects related to the Sale proceeding(to ensure a fair and unbiased process) [Docket No. 276]; (v) FTI Consulting, Inc. as investme17 bankers [Docket No. 321]; (vi) Squar Milner as accountants [Docket No. 364]; and (vii) Law Officeof A. Lavar Taylor, LLP as Special Tax Counsel [Docket No. 1679] . 18 19 L. Appointment of Committee and Retention of Committee Professionals 20 On November 10, 2015, the U.S. Trustee appointed the Committee. The initial members the Committee were the Associated Press, Pension Benefit Guaranty Corporation, Electronic Busines21 Solutions, Newscycle Solutions, Inland Empire Paper Co., Ponderay Newsprint Co., and ACCalifornia, LLC [Docket No. 77]. Electronic Business Solutions and ACI California, LLC bot22 subsequently resigned from the Committee. 23 The Committee retained (i) Pachulski Stang Ziehl & Jones LLP (“PSZ&J”) as bankruptc24 counsel and (ii) Alvarez & Marsal North America (“Alvarez”) as financial advisors. On Decemb23, 2015 and December 30, 2015, respectively, the Bankruptcy Court entered orders authorizing th25 Committee to retain PSZ&J and Alvarez [Docket Nos. 261 & 279]. The Committee also employe26 27 3 SHB is now called Shulman Bastian Friedman & Bui LLP. 4 As of the Petition Date, Alan Friedman was with the LWGF firm. Subsequently, during the Chapter 11 Cases, Mr. 28

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1 Elucidor, LLC as its expert consultant primarily in connection with the Kushner, et al. Actio(discussed below) pursuant to an order entered on June 1, 2018 [Docket No. 1508]. 2 M. Schedules, Statements of Financial Affairs 3 4 In December 2015, each of the Debtors filed its schedules of assets and liabilities anstatements of financial affairs with the Bankruptcy Court, with certain amendments filed by certain o5 the Debtors in January 2016 and August 2016. The Debtors reserve all rights to make furtheamendments to the schedules of assets and liabilities and statements of financial affairs. Copies of th6 Debtors’ Schedules are available at www.donlinrecano.com/Clients/fc/Static/SOALS. 7 N. Prosecution of Avoidance Actions 8 The Committee commenced and prosecuted over 50 separate avoidance actions in th9 Bankruptcy Court, which ultimately resulted in approximately $385,000 in recoveries (face amount) 10 V. SUMMARY OF THE JOINT CHAPTER 11 PLAN 11 This section provides a summary of the structure and means for implementation of the Pla12 and the classification and treatment of Claims and Interests under the Plan and is qualified in itentirety by reference to the Plan (as well as the Exhibits thereto and definitions therein). 13 The statements contained in this Disclosure Statement do not purport to be precise or complet14 statements of all the terms and provisions of the Plan or documents referred to therein, and referencis made to the Plan and to such documents for the full and complete statement of such terms an15 provisions. 16 The Plan itself and the documents referred to therein control the actual treatment of Claim17 against and Interests in the Debtors under the Plan and will, upon the occurrence of the Effective Datbe binding upon all Holders of Claims against and Interests in the Debtors, the Debtors’ Estates, th18 Liquidating Debtors, all parties receiving property under the Plan, and other parties in interest. In thevent of any conflict, inconsistency, or discrepancy between this Disclosure Statement and the Pla19 the Plan Supplement, or any other operative document, the terms of the Plan, Plan Supplement, and/such other operative document, as applicable, shall govern and control; provided that, in any even20 the terms of the Plan shall govern and control over all other related documents. 21 A. Purpose and Effect of the Plan 22 Chapter 11 is the chapter of the Bankruptcy Code primarily used for business reorganizatio23 Under chapter 11, a debtor is authorized to reorganize its business for the benefit of its constituentChapter 11 also allows a debtor to formulate and consummate a plan of liquidation. A plan 24 liquidation sets forth the means for satisfying claims against and interests in a debtor. Confirmatioof a plan of liquidation by a bankruptcy court makes the plan binding upon the debtor and any credito25 of or interest holder in the debtor, whether or not such creditor or interest holder (i) is impaired und26 or has accepted the plan or (ii) receives or retains any property under the plan. 27 The Plan provides for the distribution of the Debtors’ assets to various Creditors acontemplated under the Plan and for the wind-up the Debtors’ corporate affairs. More specificall28

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1 the Plan provides that a Plan Administrator will administer and liquidate all remaining property of thDebtors, including Retained Rights of Action. 2 Under the Plan, with the exception of certain Claims against the Debtors that are not require3 to be classified, Claims against, and Interests in, the Debtors are divided into certain Classes accordinto their relative seniority and other criteria. If the Plan is confirmed by the Bankruptcy Court an4 consummated, the unclassified Claims and the Claims and Interests of the various Classes will b5 treated in accordance with the applicable provisions in the Plan and the Plan Administrator will makDistributions if and as provided in the Plan. A general description of the unclassified Claims and th6 Classes of Claims and Interests created under the Plan, the treatment of those Claims and Interestunder the Plan, and the property to be distributed under the Plan are described below. 7 B. Limited Substantive Consolidation 8 Solely for purposes of voting and distribution in connection with the Plan, pursuant to Sectio9 5.2 of the Plan, the Claims and assets of the Debtors and their Estates shall be “substantivel10 consolidated” into the Estate of the Debtor FCI. This means that solely for such purposes, thseparateness of the Debtors and the Estates will be ignored and all of the Debtors and all of the Estate11 will be treated as if they were one Debtor and one Estate. 12 More specifically, on and after the Effective Date, and except as otherwise set forth in the Pla(i) all assets and liabilities of the Liquidating Debtors shall be treated as though they were pooled int13 the Liquidating Debtor FCI, (ii) each Claim filed or to be filed against any Debtor, as to which two 14 more Debtors are co-liable as a legal or contractual matter, shall be deemed filed as a single Claiagainst, and a single obligation of, the Debtors, (iii) all Claims held by a Debtor against any othe15 Debtor shall be cancelled or extinguished, (iv) no distributions shall be made under the Plan on accouof any Claim held by a Debtor against any other Debtor, (v) all guarantees of any Debtors of th16 obligations of any other Debtor shall be eliminated so that any Claim against any Debtor and anClaim based upon a guarantee thereof executed by any other Debtor shall be treated as one Clai17 against the substantively-consolidated Debtors, and (vi) any joint or several liability of any of th18 Debtors shall be one obligation of the substantively-consolidated Debtors and any Claims based uposuch joint or several liability shall be treated as one Claim against the substantively-consolidate19 Debtors. 20 The Plan is predicated on the treatment of General Unsecured Claims without regard to thspecific Debtor as to which the Holders of such Claims assert their Claims. The form of substantiv21 consolidation proposed under the Plan ultimately should benefit all Creditors. Absent the substantiv22 consolidation proposed under the Plan, the process of disentangling the Estates of the Debtors may btime consuming, costly, and may fundamentally not be feasible or practicable. For instance, allocatin23 the relative value of each Debtor’s assets that were sold in connection with the Sale would bchallenging. There is no clear apportionment of the value of the sold assets of each of the Debtors an24 the associated liabilities that were assumed. Apportioning the value of the Debtors’ assets anassociated liabilities with respect to these and other assets would be a difficult task and could lead t25 prolonged, costly disputes or litigation. 26 Further, as permitted by section 1123(a)(5)(C) of the Bankruptcy Code, one basis f27 substantive consolidation in these Chapter 11 Cases is the vote of the Class of Creditors entitled tvote in favor of such treatment. The Plan does not propose substantive consolidation to deprive 28 specific Creditor or group of Creditors of their rights while providing a windfall to other Creditor

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1 Rather, given the limited amount that may be available for distribution to Holders of GenerUnsecured Claims under the best case scenario, and the expense involved in allocating the remainin2 assets and liabilities of the Debtors among the Estates, any recovery by Creditors will be maximizeby consolidating the assets and liabilities of each of the Debtors. 3 Accordingly, the Plan Proponents believe that substantive consolidation of the Debtors, f4 purposes of voting and distribution in connection with the Plan, is in the best interest of the Debtors5 Estates and parties in interest. 6 C. Estimated Recoveries 7 The Plan Proponents estimate that Holders of Allowed General Unsecured Claims in thesChapter 11 Cases should recover approximately 0.0% to 5% of the total amount of their Allowe8 General Unsecured Claims. 9 The Plan Proponents have calculated the estimate of projected recoveries for Holders 10 General Unsecured Claims taking into account: (a) the total estimated amount of General UnsecureClaims (approximately $40 million), (b) the estimated costs of winding down the estate and amount11 required to satisfy administrative, priority, and secured claims, and (c) the total estimated amount Cash available for distributions to Holders of General Unsecured Claims. This estimate assumes th12 (i) future recoveries with respect to the Retained Rights of Action are as described herein, (ii) the totamount of Allowed Claims is not significantly different from the current estimated amount of Claim13 based on the Schedules and the proofs of claims Filed against the Debtors, and (iii) that administrativ14 priority, and secured claims are resolved in a manner consistent with the Plan Proponents’ curreestimates. 15 VI. CERTAIN PLAN PROVISIONS 16 A. Classification and Treatment of Classified Claims and Interests 17 1. Summary. 18 The categories of Claims and Interests listed below classify Claims and Interests for a19 purposes, including voting, confirmation and distribution pursuant to the Plan and pursuant to section20 1122 and 1123(a)(1) of the Bankruptcy Code. A Claim or Interest (or a portion thereof) is classifiein a particular Class only to the extent that the Claim or Interest (or a portion thereof) qualifies withi21 the description of that Class. A Claim or Interest (or a portion thereof) is also classified in a particulClass only to the extent that such Claim or Interest (or a portion thereof) is an Allowed Claim o22 Allowed Interest in that Class and has not been paid, released or otherwise satisfied prior to thEffective Date. Any postpetition payment by or on behalf of the Estates in respect of a Claim sha23 reduce the Allowed amount thereof. 24 2. Classification and Treatment of Claims and Interests. 25 Class 1 – Priority Non-Tax Claims. 26 (a) Classification: Class 1 consists of all Priority Non-Tax Claims. The Debtors estimat27 that the aggregate amount of unpaid Priority Non-Tax Claims as of the Effective Date will bapproximately $1,000,000.00. 28

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1 (b) Treatment: At the election of the Liquidating Debtors, each Holder of a Priority NoTax Claim shall receive, in full satisfaction, settlement, release, and extinguishment of such Priorit2 Non-Tax Claim, on or as soon as practicable after the later of (i) the Effective Date, or (ii) thirty (30calendar days following the date on which such Priority Non-Tax Claim becomes an Allowed Priorit3 Non-Tax Claim, (a) a Cash payment from the Liquidating Debtors equal to the Allowed amount 4 such Claim, or (b) such other treatment as otherwise agreed by the Holder of such Claim and thDebtors or the Liquidating Debtors. 5 (c) Impairment/Voting: Class 1 Priority Non-Tax Claims are Unimpaired by the Plan, an6 Holders of such Class 1 Priority Non-Tax Claims are therefore conclusively presumed to havaccepted the Plan pursuant to section 1126(f) of the Bankruptcy Code. Accordingly, Holders of Clas7 1 Priority Non-Tax Claims are not entitled to vote to accept or reject the Plan. 8 Class 2 – Miscellaneous Secured Claims. 9 (a) Classification: Class 2 consists of any Miscellaneous Secured Claims. Although a10 Miscellaneous Secured Claims have been placed in one Class for the purposes of nomenclature, eacMiscellaneous Secured Claim, to the extent secured by a Lien on any property or interest in propert11 of any of the Debtors different from that securing any other Miscellaneous Secured Claim, shall btreated as being in a separate sub-Class for purposes of voting and receiving distributions under th12 Plan. The Debtors estimate that the aggregate amount of unpaid Miscellaneous Secured Claims as 13 the Effective Date will be approximately $200,000. 14 (b) Treatment: Except to the extent that a Holder of an Allowed Miscellaneous SecureClaim has been paid by the Debtors, in whole or in part, prior to the Effective Date, on the later o15 (i) the Effective Date and (ii) thirty (30) calendar days following the date on which such MiscellaneouSecured Claim becomes an Allowed Miscellaneous Secured Claim, at the option of the Liquidatin16 Debtors, in full and final satisfaction of such Miscellaneous Secured Claim, (i) each AlloweMiscellaneous Secured Claim shall be reinstated and Unimpaired in accordance with section 1124 o17 the Bankruptcy Code, or (ii) each Holder of an Allowed Miscellaneous Secured Claim shall receiv18 in full satisfaction, settlement, and release of, and in exchange for, such Miscellaneous Secured Clai(x) payment in full in Cash of the unpaid portion of such Allowed Miscellaneous Secured Claim, (y19 the collateral securing such Allowed Miscellaneous Secured Claim, or (z) such other treatment as mabe agreed to by the Holder of such Claim and the Debtors or the Liquidating Debtors. 20 (c) Impairment/Voting: Class 2 Miscellaneous Secured Claims are Unimpaired by th21 Plan, and Holders of such Class 2 Miscellaneous Secured Claims are therefore conclusively presume22 to have accepted the Plan pursuant to section 1126(f) of the Bankruptcy Code. Accordingly, Holderof Class 2 Miscellaneous Secured Claims are not entitled to vote to accept or reject the Plan. 23 Class 3 – General Unsecured Claims. 24 (a) Classification: Class 3 consists of all General Unsecured Claims, which does n25 include the PBGC Unsecured Claims. The Debtors estimate that, ultimately, Allowed Class 3 GenerUnsecured Claims will total approximately $40 million. 26 27 (b) Treatment: Except to the extent that a Holder of an Allowed Class 3 General UnsecureClaim agrees to a less favorable treatment, in exchange for full and final satisfaction, settlement an28 release of the each Allowed Class 3 General Unsecured Claim, each Holder of an Allowed Class

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1 General Unsecured Claim shall receive a Cash payment equal to its Pro Rata share of the NDistributable Estate Assets on one or more dates (the “Class 3 Distribution Date(s|)”) as soon a2 reasonably practicable after (i) all General Unsecured Claims have been Allowed, Disallowed otherwise resolved and (ii) the payment of (or reserves for) all Allowed Administrative Expense3 Allowed Priority Tax Claims, Allowed Priority Non-Tax Claims, Allowed Miscellaneous Secure4 Claims and Plan Expenses (unless the holder of the applicable claim agrees to other less favorabltreatment); provided, however, in the event that an aggregate of at least $1,000,000 in Cash in N5 Distributable Assets is or will be distributed, as Distributions under the Plan, to the Holders of AlloweClass 3 General Unsecured Claims on account of such Claims (the “Pro Rata Class 3 / Class 6 Distribution Trigger Event”), any and all Net Distributable Assets in excess of such $1,000,000 Casthreshold (the “Excess Net Distributable Assets”) shall be distributed by the Liquidating Debtors t7 the Holders of Allowed Class 3 Claims and the PBGC (or other Holder of the Class 4 Claims), o8 account of their Class 3 and Class 4 Claims, respectively, on a Pro Rata basis as soon as reasonablpracticable on the Class 3 Distribution Date(s); provided further that in the discretion of the Pla9 Administrator, Allowed Class 3 General Unsecured Claims may receive Distributions before threconciliation of all Disputed Class 3 General Unsecured Claims provided that (x) reserves ar10 maintained for any Class 3 General Unsecured Claim that is Disputed at the time of such Distributioand (y) the Plan Administrator shall make a corrective Distribution following the resolution of an11 Disputed Claim within thirty (30) days of such resolution. 12 (c) Impairment/Voting: Class 3 Prepetition Lender Claims are Impaired. Holders of Clas13 3 Prepetition Lender Claims are therefore entitled to vote to accept or reject the Plan. 14 Class 4 – PBGC Unsecured Claims. 15 (a) Classification: Class 4 consists of all PBGC Unsecured Claims. 16 (b) Treatment: The Holder of the PBGC Unsecured Claims shall receive the treatmeprovided for the PBGC on account of the PBGC Unsecured Claims set forth in the PBGC Settlemen17 Specifically, pursuant to the PBGC Settlement, the PBGC has agreed to waive any right to receiv18 Distributions under the Plan, on account of the PBGC Unsecured Claims, unless and until the Pro RatClass 3 / Class 4 Distribution Trigger Event occurs or is otherwise satisfied; upon the occurrence o19 the Pro Rata Class 3 / Class 4 Distribution Trigger Event, the PBGC shall be entitled to share on a PrRata basis with the Holders of Allowed Class 3 Claims any Excess Net Distributable Assets. Nothin20 in the Plan is intended to or will modify the PBGC Settlement, and in the event of any discrepancbetween the treatment noted above and the treatment provided for the PBGC under the PBG21 Settlement, the terms of the PBGC Settlement govern. 22 (c) Impairment/Voting: Class 4 PBGC Unsecured Claims are Impaired under the Pla23 The Holder of such Class 4 Claims are entitled to vote to accept or reject the Plan. 24 Class 5 – Interests in the Debtors. 25 (a) Classification: Class 5 consists of all Interests. 26 (b) Treatment: Holders of Interests shall receive no distributions under the Plan, and on th27 Effective Date, all Interests shall be deemed void and of no force and effect. 28

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1 (c) Impairment/Voting: Class 5 Interests are Impaired, and Holders of such Class Interests are deemed to have rejected the Plan pursuant to section 1126(g) of the Bankruptcy Cod2 Therefore, Holders of Class 5 Interests are not entitled to vote to accept or reject the Plan. 3 B. Acceptance of Rejection of the Plan 4 1. Classes Permitted and Not Permitted to Vote. 5 Classes 1 and 2 are Unimpaired. Holders of Claims in these Classes are conclusively presume6 pursuant to section 1126(f) of the Bankruptcy Code to have accepted the Plan and therefore shall nbe entitled to vote to accept or reject the Plan. Classes 3, 4 and 5 are Impaired. Holders of Claims i7 Classes 3 and 4 are permitted to vote to accept or reject the Plan. Holders of Interests in Class 5 ardeemed to reject the Plan pursuant to section 1126(g) of the Bankruptcy Code. The Plan Proponent8 reserve all rights with respect to all Claims and Interests classified by the Plan. An Impaired Class oClaims that votes shall have accepted the Plan if (a) the Holders of at least two-thirds in amount of th9 Allowed Claims actually voting in such Class have voted to accept the Plan and (b) the Holders o10 more than one-half in number of the Allowed Claims actually voting in such Class have voted to accethe Plan. Section 1129(a)(10) of the Bankruptcy Code shall be satisfied for purposes of Confirmatio11 by acceptance of the Plan by an Impaired Class of Claims. 12 2. Effect of Non-Voting. 13 If no Holder of a Claim eligible to vote in a particular Class timely votes to accept or reject th14 Plan, the Plan Proponents may seek to have the Plan deemed accepted by the Holders of such Claimin such Class for purposes of section 1129 of the Bankruptcy Code. 15 3. Nonconsensual Confirmation. 16 In the event any Class of Claims votes to reject the Plan and given the deemed rejection of th17 Plan by the Holders of Interests in Class 5, the Plan Proponents request that the Bankruptcy Couconfirm the Plan notwithstanding such rejection pursuant to section 1129(b) of the Bankruptcy Cod18 on the basis that the Plan is fair and equitable and does not discriminate unfairly as to the Holders 19 any Class of Claims or Interests. 20 4. Postpetition Interest. 21 Nothing in the Plan or the Disclosure Statement shall be deemed to entitle the Holder of Claim to receive postpetition interest on account of such Claim, except to the extent that the Hold22 of a Claim has the benefit of a Lien on assets the value of which exceeds the amount of such Claim the Plan expressly provides for postpetition interest on account of such Claim. 23 24 5. Elimination of Vacant Classes. 25 Any Class of Claims or Interests that does not have a Holder of an Allowed Claim or AlloweInterest or a Claim or Interest temporarily Allowed by the Bankruptcy Court in an amount greater tha26 zero as of the date of the Confirmation Hearing shall be considered vacant and deemed eliminatefrom the Plan for purposes of voting to accept or reject the Plan and for purposes of determinin27 acceptance or rejection of the Plan by such Class pursuant to section 1129(a)(8) of the BankruptcCode. 28

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1 6. Special Provisions Regarding Insured Claims. 2 With respect to any Insured Claim, any party with rights against or under the applicablinsurance policy may pursue such rights. Nothing in the Plan shall constitute a waiver of any cause3 of action the Debtors or the Liquidating Debtors may hold against any Person, including the Debtorinsurance carriers; and nothing in the Plan is intended to, shall, or shall be deemed to preclude an4 Holder of an Allowed Insured Claim from seeking and/or obtaining a distribution or other recover5 from any insurer of the Debtors in addition to (but not in duplication of) any Distribution such Holdmay receive under the Plan; provided, however, that the Debtors and the Liquidating Debtors do n6 waive, and expressly reserve their rights to assert that any insurance coverage is property of the Estateto which they are entitled. 7 The Plan shall not modify the scope of, or alter in any other way, the rights and obligations 8 the Debtors’ insurers under their policies, and the Debtors’ insurers shall retain any and all right9 claims and defenses to liability and/or coverage that such insurers may have, including the right tcontest and/or litigate with any party the existence, primacy and/or scope of liability and/or availabl10 coverage under any alleged applicable policy. The Plan shall not operate as a waiver of any otheClaims the Debtors’ insurers have asserted or may assert in any proof of claim, including, witho11 limitation, any rights or defenses arising out of, or in the nature of, setoff or recoupment, or thDebtors’ rights and defenses to such proofs of claim. 12 13 C. Means for Implementation of the Plan 14 1. Settlement of Intercompany Claims. 15 Upon the Effective Date, pursuant to section 1123(b) of the Bankruptcy Code and BankruptcRule 9019, each Debtor and their successors and assigns hereby waive and release each other and a16 of their respective successors from any and all Intercompany Claims and Rights of Action among anbetween any or all of the Debtors, which waiver and release shall be effective as a bar to all action17 causes of action, suits, Claims, Liens, or demands of any kind with respect to any Intercompany Clai18 or Right of Action among or between any or all of the Debtors. 19 2. Partial Substantive Consolidation. 20 In furtherance of the settlements contained in the Plan, the entry of the Confirmation Ordeshall constitute approval by the Bankruptcy Court, pursuant to sections 105(a) and 1123(a)(5)(C) 21 the Bankruptcy Code, as of the Effective Date, of the substantive consolidation of the Debtors antheir respective Estates into the Estate of Debtor FCI, solely for purposes of voting and distribution22 under the Plan. Pursuant to the Confirmation Order, on and after the Effective Date, (i) a23 Distributable Assets to be used for distributions to Creditors of any of the Debtors will be treated athough they were merged into Liquidating Debtor FCI; and (ii) any obligation of any Debtor and a24 guarantees thereof executed by, or joint liability of, any of the Debtors will be treated as one obligatioof Liquidating Debtor FCI for distribution purposes pursuant to the Plan. 25 Notwithstanding the foregoing, the substantive consolidation of the Debtors for voting an26 distribution purposes shall not affect or impair (i) any rights, Claims, remedies or defenses of (27 between) the separate Debtors as of the Petition Date, including with respect to any Retained Rightof Action; (ii) the legal and organizational structure of the Debtors; (iii) any Liens that are maintaine28

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1 recognized, or preserved under the Plan; and (iv) claims under or with respect to any insurance policof any Debtor (or any right to the proceeds of any such policy or policies). 2 The Disclosure Statement and the Plan shall be deemed to be a motion by the Plan Proponent3 for substantive consolidation. Any objection by an affected Creditor to such consolidation shall btreated as an objection to Confirmation and shall be determined by the Bankruptcy Court in the conte4 of considering Confirmation of the Plan. 5 If the Bankruptcy Court determines that substantive consolidation of any given Debtor(s) i6 not appropriate, then the Plan Proponents may request that the Bankruptcy Court otherwise confirthe Plan and approve the treatment of and distributions to the different Classes under the Plan on a7 adjusted, Debtor-by-Debtor basis. Furthermore, the Plan Proponents reserve their rights to seeConfirmation of the Plan without implementing substantive consolidation of any given Debtor, an8 in the Plan Proponents’ discretion, to request that the Bankruptcy Court approve the treatment of an9 distributions to any given Class under the Plan on an adjusted, Debtor-by-Debtor basis. 10 Notwithstanding the substantive consolidation called for herein and in the Plan, each and everDebtor shall remain responsible for the payment of U.S. Trustee fees pursuant to 28 U.S.C. § 19311 until its particular case is closed; provided, however, the Debtors or some of them may apply to closthe cases of those Debtors following Confirmation. 12 3. Continued Corporate Existence and Vesting of Assets. 13 14 On and after the Effective Date, subject to the requirements of the Plan, the LiquidatinDebtors will continue to exist as separate corporations or limited liability companies (as applicable15 and shall retain all of the powers of corporations or limited liability companies (as applicable) undapplicable non-bankruptcy law, and without prejudice to any right to amend their respective operatin16 agreement, dissolve, merge or convert into another form of business entity, or to alter or terminattheir existence. The existing stock, membership and/or other equity interests (as applicable) of th17 Debtors shall be deemed to be held through the Plan Administrator. Further, the Debtors’ bylaw18 operating agreements, and/or other corporate governance documents (as applicable) shall be deemeto include a provision prohibiting the issuance of nonvoting equity securities and such other provision19 as may be required pursuant to section 1123(a)(6) of the Bankruptcy Code. 20 Except as otherwise provided in the Plan, on and after the Effective Date, all DistributablAssets and property of the Debtors and their Estates, including any interests in subsidiaries an21 affiliates and any Retained Rights of Action of the Debtors, will vest in Liquidating Debtor FCI freand clear of all Claims, Liens, charges, other encumbrances and Interests. Neither the occurrence o22 the Effective Date, nor the effectiveness of the Plan, nor any provision of applicable non-bankruptc23 law shall cause a dissolution of the Debtors, which shall be continued as corporations or limiteliability companies (as applicable) following the Effective Date subject to the terms of the Plan. 24 On and after the Effective Date, subject to the requirements of the Plan, the Liquidatin25 Debtors shall be permitted to conduct their business (to the extent permitted by the Plan), reconcilClaims, use and dispose of assets, prosecute litigation, make required tax filings, and otherwise tak26 any and all actions as may be appropriate to implement the Plan without supervision by the Bankruptc27 Court and free of any restrictions under the Bankruptcy Code or the Bankruptcy Rules. ThLiquidating Debtors shall be authorized, without limitation, to use and dispose of the Distributabl28 Assets of the Debtors and their Estates, to investigate and pursue any Retained Rights of Action as th

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1 representative of the Debtors’ Estates pursuant to section 1123(b)(3)(B) of the Bankruptcy Code, tacquire and dispose of other property, and to otherwise administer their affairs. 2 4. Corporate Action; Winding Up of Affairs. 3 On the Effective Date, the matters under the Plan involving or requiring, as applicabl4 corporate or limited liability company action of the members, managers, directors, or officers of th5 Debtors, including but not limited to actions requiring a vote or other approval of, as applicable, thboard of managers or board of directors or any of the members or officers of the Debtors or th6 execution of any documentation incident to or in furtherance of the Plan, shall be deemed to have beeauthorized by the Confirmation Order and to have occurred and be in effect from and after th7 Effective Date, without any further action by the Bankruptcy Court or the members, managerdirectors, or officers of the Debtors. 8 Without limiting the generality of the foregoing, on the Effective Date and automatically an9 without further action, (i) any existing director, manager and officer of the Debtors will be deemed t10 have resigned on the Effective Date without any further corporate action, (ii) the Plan Administratshall be deemed the sole manager, director, officer and representative of the Liquidating Debtors t11 exercise the rights, power and authority of the Liquidating Debtors under applicable provisions of thPlan and bankruptcy and non-bankruptcy law, and (iii) all matters provided under the Plan shall b12 deemed to be authorized and approved without further approval from the Bankruptcy Court. Th13 Confirmation Order shall modify the Debtors’ operating agreements, bylaws and any other corporatgovernance documents such that the provisions of the Plan can be effectuated. The Plan shall b14 administered by the Plan Administrator, and all actions taken thereunder in the name of the LiquidatinDebtors shall be taken through the Plan Administrator. All corporate governance activities of th15 Liquidating Debtors shall be exercised by the Plan Administrator in his or her discretion, subject tthe terms of the Plan. 16 Following the Confirmation Date, the Liquidating Debtors shall not engage in any busines17 activities or take any actions, except those necessary or appropriate to (i) effectuate the Plan an18 (ii) dispose of their assets and wind up the affairs of the Debtors and their Estates as soon as reasonablpracticable. On and after the Effective Date, the Plan Administrator may, in the name of th19 Liquidating Debtors, take such actions without supervision or approval by the Bankruptcy Court anfree of any restrictions of the Bankruptcy Code or the Bankruptcy Rules, other than any restriction20 expressly imposed by the Plan or the Confirmation Order. Without limiting the foregoing, the PlaAdministrator may, without application to or approval of the Bankruptcy Court, pay, from the proceed21 of Distributable Assets, the charges that he or she incurs after the Effective Date for professional fee22 and expenses that, but for the occurrence of the Effective Date, would constitute AlloweAdministrative Expenses. 23 From and after the Effective Date, (i) the Debtors, for all purposes, shall be deemed to hav24 withdrawn their business operations from any state or territory in which they were previouslconducting or are registered or licensed to conduct their business operations, and the Debtors shall n25 be required to file any document, pay any sum or take any other action, in order to effectuate suc26 withdrawal, and (ii) the Debtors shall not be liable in any manner to any taxing authority for franchisbusiness, license or similar taxes accruing on or after the Effective Date. 27 Pursuant to section 1146(c) of the Bankruptcy Code, any transfers effected pursuant to the Pla28 shall not be subject to any document recording tax, stamp tax, conveyance fee, intangibles or simil

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1 tax, mortgage tax, stamp act, real estate transfer tax, mortgage recording tax or other similar tax ogovernmental assessment. 2 5. Plan Administrator. 3 On the Effective Date, the Plan Administrator shall begin acting for the Liquidating Debtor4 in the same fiduciary capacity as applicable to a board of directors of a Delaware corporatio5 implementing such liquidation and wind-down as contemplated under the Plan, subject to thprovisions hereof. The Plan Administrator shall serve in such capacity through the earlier of the dat6 that all of the Debtors are dissolved in accordance with the Plan and the date such Plan Administratresigns, is terminated or otherwise unable to serve; provided, however, that any successor Pla7 Administrator appointed pursuant to the Plan shall serve in such capacity after the effective date such person’s appointment as Plan Administrator. 8 The qualifications and proposed compensation of and other disclosures regarding the Pla9 Administrator shall be set forth as part of the Plan Supplement; such compensation may be paid fro10 the Liquidating Debtors’ Cash on hand, without further notice or order of the Bankruptcy CourFurther, the Plan Administrator shall be entitled to reimbursement, from the Liquidating Debtors’ Cas11 on hand, for his or her actual, reasonable, and necessary expenses incurred in connection with thperformance of his or her duties, without the need for further notice or Bankruptcy Court approva12 All distributions to be made to Creditors under the Plan shall be made by the Plan Administrator (o13 his or her designated agent). The Plan Administrator shall deposit and hold all Cash in trust for thbenefit of Creditors (including Professional Persons) receiving distributions under the Plan. The dutie14 and powers of the Plan Administrator shall include, without limitation, the following (without need ofurther Court approval): 15 (i) To exercise all power and authority that may be exercised, to commence all 16 proceedings (including the power to continue any actions and proceedings that may have been commenced by the Debtors prior to the Effective Date) that may be 17 commenced, and to take all actions that may be taken by any officer, director, or 18 manager of the Liquidating Debtors with like effect as if authorized, exercised, and taken by unanimous action of such officers, directors, and managers, including 19 consummating the Plan and all transfers thereunder on behalf of the Liquidating Debtors; 20 (ii) To wind up the affairs of the Liquidating Debtors and any or all of their 21 subsidiaries and affiliates and their Estates to the extent appropriate as expeditiously 22 as reasonably possible; 23 (iii) To maintain all accounts, make distributions, and take other actions required under or consistent with the Plan, including the maintenance of appropriate reserves, 24 in the name of the Liquidating Debtors; 25 (iv) To use, manage, sell, abandon, convert to Cash and/or otherwise dispose of the Distributable Assets for the purpose of liquidating or otherwise disposing of all 26 remaining property of the Estates, making distributions and fully consummating the 27 Plan; 28

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1 (v) To take all steps necessary or appropriate to terminate the corporate existence of the Debtors consistent with the Plan; 2 (vi) To prosecute objections to Claims and Interests, and to compromise or settle any3 Claims or Interests (Disputed or otherwise); 4 (vii) To prosecute any and all Retained Rights of Action and compromise or settle 5 any Retained Rights of Action; provided, however, the Plan Administrator will not, on behalf of the Debtors and Liquidating Debtors, prosecute or otherwise pursue any 6 Avoidance Claims after the Effective Date; 7 (viii) To prepare and file tax returns to the extent required by law; 8 (ix) To employ and compensate any and all such professionals and agents as the PlanAdministrator, in his or her sole discretion, deems appropriate to perform his or her 9 duties under the Plan without further order of the Bankruptcy Court; and 10 (x) To take all other actions not inconsistent with the provisions of the Plan that the 11 Plan Administrator deems reasonably necessary or desirable in connection with the administration of the Plan, including, without limitation, filing all motions, pleadings12 reports, and other documents in connection with the administration and closing of thChapter 11 Cases. 13 The Plan Administrator may be removed by the Bankruptcy Court upon application for goo14 cause shown. In the event of the resignation, removal, death, or incapacity of the Plan Administrato15 the Bankruptcy Court shall, upon motion or sua sponte, appoint another Person to become PlaAdministrator, with notice thereof provided to the Post-Effective Date Service List. Any success16 Plan Administrator, without any further act, shall become fully vested with all of the rights, powerduties, and obligations of his or her predecessor. 17 6. Source of Funding. 18 The source of all distributions and payments under the Plan will be the Distributable Asset19 and the proceeds thereof, including, without limitation, the Debtors’ Cash on hand and proceeds fro20 any sale or other disposition of the Debtors’ assets and prosecution of Retained Rights of Action. 21 The Debtors estimate that, as of the Effective Date, the Debtors’ Cash on hand will bapproximately $6,500,000.00. This estimated amount of Cash is based on the assumption that th22 Debtors will ultimately receive approximately $5,000,000 in connection with the Refund Clai(defined below). 23 24 7. Retained Rights of Action. 25 In accordance with section 1123(b) of the Bankruptcy Code, the Liquidating Debtors sharetain and may enforce all rights to commence and pursue, as appropriate, any and all Retained Right26 of Action, whether arising before or after the Petition Date, including any actions specificallenumerated in the Plan Supplement, and the Liquidating Debtors’ rights to commence, prosecute, o27 settle such Retained Rights of Action shall be preserved notwithstanding the occurrence of thEffective Date. The Plan Administrator may pursue such Retained Rights of Action, as appropriat28

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1 Administrator will not, on behalf of the Debtors and Liquidating Debtors, prosecute or otherwispursue any Avoidance Claims after the Effective Date. No Person may rely on the absence of 2 specific reference in the Plan, the Plan Supplement, or the Disclosure Statement to any RetaineRight of Action against it as any indication that the Debtors or Liquidating Debtors, a3 applicable, will not pursue any and all available Retained Rights of Action against it. Th4 Debtors or Liquidating Debtors, as applicable, expressly reserve all rights to prosecute any anall Retained Rights of Action against any Person, except as otherwise expressly provided in th5 Plan. Unless any Right of Action is expressly waived, relinquished, exculpated, releasecompromised, or settled in the Plan or a Bankruptcy Court order, the Debtors and the Liquidatin6 Debtors expressly reserve all Rights of Action for later adjudication, and, therefore, no preclusiodoctrine, including the doctrines of res judicata, collateral estoppel, issue preclusion, claim preclusio7 estoppel (judicial, equitable, or otherwise), or laches shall apply to such Retained Rights of Actio8 upon, after, or as a consequence of Confirmation or Consummation of the Plan. 9 Among the Debtors’ “Retained Rights of Action” is the Debtors’ entitlement to a substantitax refund (the “Refund Claim”) from the CDTFA5 . The Debtors’ sales and use tax returns for th10 periods November 1, 2012 through March 31, 2016 were audited by the CDTFA. FreedoCommunications, Inc. and Freedom Communications Holdings, Inc. previously submitted claims f11 refunds totaling in excess of $7.4 million combined to the CDTFA for these same periods of time. I12 February 2020, the CDTFA auditor issued letters setting forth their preliminary audit conclusionThese preliminary conclusions provided for the allowance of refunds totaling approximatel13 $692,003.50 for Freedom Communications, Inc. for pre-petition tax periods while asserting a pospetition administrative expense claim of $660,494.36. These preliminary conclusions also provide14 for the allowance of refunds totaling approximately $27,777.70 for Freedom CommunicationHoldings, Inc. for pre-petition tax periods while asserting a post-petition administrative expense clai15 of $311,341.28. The Debtors did not agree with these preliminary conclusions. 16 The Debtors attended a meeting with the CDTFA’s Principal Auditor on June 23, 20217 regarding the preliminary conclusions. There were several unresolved issues with the CDTFA audat that time. The most significant issues included: (1) the allocation of home delivery subscriptio18 revenue between digital sales, which are not taxable, and print sales, which are taxable; (2) the portioof the home subscription price which is allocated to “delivery services”; (3) single copy newspaper19 sold to distributors for resale being treated as taxable transactions; (4) certain commercial print revenutransactions being treated as taxable; and (5) allocating too much of the purchase price of the asset20 sold in 2016 to the sale of tangible personal property, as opposed to the sale of intangible assets (whic21 are not taxable). Following this meeting, the Debtors submitted their contentions to the CDTFA’Principal Auditor. In or about October, 2020, the CDTFA issued its final audit reports. In Novembe22 2020, the Debtors commenced the administrative appeal process with respect to the final audit report23 In February, 2021, the Debtors filed that certain “Motion of Debtors and Debtors in PossessioUnder Bankruptcy Code Section 502(c) to Estimate Claim of the California Department of Taxatio24 Fee Administration (“CDTFA”) and to Determine that CDTFA Owes Debtors Refunds in Excess 25 the Claims of the CDTFA, etc.” [Docket No. 1725] (the “Estimation Motion”). By the EstimatioMotion, the Debtors sought an order of the Bankruptcy Court, that among other things, estimated th26 27 28 5

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1 Debtors’ Refund Claim in the aggregate approximate amount of $5 million, and further estimating thCDTFA’s prepetition claims at $0 and the aggregate post-petition claims at approximately $55,000. 2 The CDTFA filed its opposition [Docket No. 1732] to the Estimation Motion (the “ Estimatio3 Opposition”) pursuant to which it raised technical issues regarding the Bankruptcy Court’s ability tgrant the relief requested by the Debtors. In addition, the CDTFA contested the Debtors’ position4 regarding the amount of the CDTFA’s asserted claims and the amount of the Refund Claim on th5 merits6. 6 The primary purpose of the Estimation Motion was to establish the feasibility of the DebtorsPlan. Based upon primarily technical arguments asserted by the CDTFA in the Estimation Oppositio7 the Bankruptcy Court denied the Estimation Motion with prejudice. However, the Bankruptcy Coufurther stated that while it was not prejudging or actually deciding the merits of the Refund Clai8 based on the information presented in connection with the Estimation Motion, "the Court finds tha9 solely for purposes of determining the feasibility of a plan of reorganization, it is more likely than nthat the Debtors will recover refunds from the CDTFA in amounts sufficient to fund a Chapter 110 Plan" [Docket No. 1749]. it was more probable than not that the Debtors would obtain refunds, anlimit the CDTFA’s claims, in the amounts stated in the Estimation Motion. The CDTFA disagree11 with the Bankruptcy Court’s views in this regard. The Debtors intend to commence in the immediatfuture an adversary proceeding pursuant to Bankruptcy Code Section 505 in order to obtain 12 determination of the amount of the Refund Claim. The Debtors will also be filing formal claim13 objections with respect to the claims being asserted by the CDTFA. 14 While the Debtors will incur additional administrative expenses pursuing the Refund Claithe Refund Claim is the only significant remaining source of funds to pay claims under the Pla15 Given the potential magnitude of the Refund Claim, the Plan Proponents believe the incurrence additional administrative expenses is warranted. 16 In accordance with section 1123(b)(3) of the Bankruptcy Code, any Retained Rights of Actio17 shall vest in the Liquidating Debtors. The Liquidating Debtors shall have standing as th18 representative of the Debtors’ Estates pursuant to section 1123(b)(3)(B) of the Bankruptcy Code tpursue, or decline to pursue, the Retained Rights of Action and objections to Claims, as appropriat19 in the business judgment of the Plan Administrator. The Liquidating Debtors, acting through the PlaAdministrator, may settle, release, sell, assign, otherwise transfer, or compromise Retained Rights o20 Action and/or objections to Claims without need for notice or order of the Bankruptcy Court. 21 8. Interests in Non-Debtors Affiliates and Subsidiaries. 22 As of the Effective Date, except as expressly provided in the Plan or by separate order of th23 Bankruptcy Court, the Liquidating Debtors shall retain any stock or interests that they may hold itheir non-Debtor affiliates or subsidiaries and retain any rights to which such stock or interests ma24 6 The CDTFA took similar positions, albeit in a more summary fashion, in connection with its 25 opposition to the Debtors’ First Amended Disclosure Statement (the “Disclosure Statement 26 Opposition”) [Docket No. 1705] , and in summary, contended, among other things, that the DebtorsPlan was not feasible. The Disclosure Statement Opposition was filed prior to the resolution of the 27 Estimation Motion. The Bankruptcy Court’s ruling in connection with the Estimation Motion, discussed, infra, along with other changes set forth in the Disclosure Statement, have resolved the 28

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1 be entitled under applicable law with respect to such shares or other interests. After the EffectivDate, the Liquidating Debtors may sell, transfer, assign or otherwise dispose of such shares or interest2 as permitted by applicable law. 3 9. Payment of Plan Expenses. 4 The Liquidating Debtors may pay all reasonable Plan Expenses without further notice t5 Creditors or Holders of Interests or approval of the Bankruptcy Court. 6 10. Dissolution of Debtors; Final Decree. 7 Once the Plan Administrator determines that the Final Resolution Date has occurred as to anof the Liquidating Debtors, such Liquidating Debtors shall be dissolved for all purposes by the Pla8 Administrator without the necessity for any other or further actions to be taken by or on behalf of anLiquidating Debtors or payments to be made in connection therewith; provided, however, that, witho9 the need of any further approval, the Plan Administrator in his or her discretion may execute and fil10 documents and take all other actions as he or she deems appropriate relating to the dissolution of thLiquidating Debtors under the laws of Delaware and/or any other applicable states, and in such even11 all applicable regulatory or governmental agencies shall take all steps necessary to allow and effethe prompt dissolution of the Liquidating Debtors as provided in the Plan, without the payment of an12 fee, tax, or charge and without need for the filing of certificates. At any time following the EffectivDate, the Plan Administrator, on behalf of the Liquidating Debtors, shall be authorized to move f13 the entry of a final decree closing any or all of the Chapter 11 Cases pursuant to section 350 of th14 Bankruptcy Code. 15 11. Records. 16 The Liquidating Debtors and Plan Administrator shall maintain reasonably good and sufficiebooks and records of accounting relating to the Distributable Assets, the Liquidating Debtors’ Cas17 the management thereof, all transactions undertaken by such parties, all expenses incurred by or obehalf of the Liquidating Debtors and Plan Administrator, and all distributions contemplated 18 effectuated under the Plan. Upon the entry of a final decree closing the Chapter 11 Cases, unles19 otherwise ordered by the Bankruptcy Court, the Liquidating Debtors and Plan Administrator madestroy or otherwise dispose of all records maintained by the Liquidating Debtors and/or Pla20 Administrator. Notwithstanding anything to the contrary, the Plan Administrator may, upon notice tthe Post-Effective Date Service List and without Bankruptcy Court approval, destroy any document21 that he or she believes are no longer required to effectuate the terms and conditions of the Plan. 22 D. Treatment of Executory Contracts and Unexpired Leases 23 1. Rejection of Executory Contracts and Unexpired Leases. 24 Except for any executory contracts or unexpired leases: (i) that previously were assume25 assumed and assigned, or rejected by an order of the Bankruptcy Court, pursuant to section 365 of thBankruptcy Code; (ii) that are listed for assumption by the Debtors as of the Effective Date in a Pla26 Supplement to be filed and served on affected non-Debtor counterparties; (iii) as to which a motiofor approval of the assumption or rejection of such contract or lease has been Filed and served pri27 to the Effective Date; (iv) that constitute contracts of insurance in favor of, or that benefit, the Debtor28 or the Estates; or (v) that were previously sold, conveyed or otherwise assigned pursuant to Fin

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1 Order, each executory contract and unexpired lease entered into by the Debtors prior to the PetitioDate that has not previously expired or terminated pursuant to its own terms shall be deemed rejecte2 pursuant to section 365 of the Bankruptcy Code as of the Effective Date. Without limiting thforegoing, the indemnification obligations in favor of the Debtors’ current directors, officer3 managers, and representatives, to the extent not previously rejected, shall be assumed as of th4 Effective Date, and all other pre-Effective Date indemnification obligations of the Debtors shall bdeemed rejected as of the Effective Date to the extent that such obligations are contained in executor5 contracts within the meaning of section 365 of the Bankruptcy Code, but only to the extent ninconsistent with any existing insurance obligations. The Confirmation Order shall constitute an orde6 of the Bankruptcy Court approving such assumptions or rejections, pursuant to section 365 of thBankruptcy Code, as of the Effective Date. 7 8 2. Bar Date for Rejection Claims. 9 If the rejection of an executory contract or unexpired lease pursuant to the Plan or otherwisgives rise to a Claim by the other party or parties to such contract or lease, such Claim shall be forev10 barred and shall not be enforceable against the Debtors or their Estates unless a proof of Claim is Fileand served on the Plan Administrator and its counsel within thirty (30) calendar days after the earlie11 of (a) the Effective Date and (b) service of a notice that the executory contract or unexpired lease habeen rejected. All such Claims for which proofs of Claim are required to be Filed, if Allowed, wi12 be, and will be treated as, General Unsecured Claims, subject to the provisions of the Plan. 13 E. Distributions and Related Matters 14 1. Dates of Distribution. 15 Whenever any payment or distribution to be made under the Plan shall be due on a day oth16 than a Business Day, such payment or distribution shall instead be made, without interest, by thLiquidating Debtors (or their agent) on the immediately following Business Day. 17 2. Cash Distributions. 18 19 Distributions of Cash may be made either by check drawn on a domestic bank or wire or ACtransfer from a domestic bank, at the option of the Liquidating Debtors, except that Cash payment20 made to foreign Creditors may be made in such funds and by such means as are necessary or customarin a particular foreign jurisdiction. 21 3. Rounding of Payments. 22 Whenever payment of a fraction of a cent would otherwise be called for, the actual payme23 shall reflect a rounding down of such fraction to the nearest whole cent. To the extent Cash remain24 undistributed as a result of the rounding of such fraction to the nearest whole cent, such Cash shall btreated as “Unclaimed Property” under the Plan. 25 4. Disputed Claims. 26 Notwithstanding all references in the Plan to Claims that are Allowed, solely for the purpos27 of calculating (but not distributing) the amount or number of distributions to be made on account Allowed Class 3 General Unsecured Claims under the Plan, such calculations may be made, in th28

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1 the Bankruptcy Court estimates the likely portion of a Disputed Claim to be Allowed or authorized otherwise determines the amount or number which would constitute a sufficient reserve for a Dispute2 Claim (which estimates and determinations may be requested by the Liquidating Debtors), sucamount or number as determined by the Bankruptcy Court may be used for calculations as to suc3 Disputed Claim instead. 4 5. Undeliverable and Unclaimed Distributions. 5 In the event that any distribution to any Holder is returned as undeliverable, no distribution t6 such Holder shall be made unless and until the Plan Administrator has determined the then curreaddress of such Holder, at which time such distribution shall be made to such Holder without interes7 provided, however, that such distributions shall be deemed Unclaimed Property at the expiration oninety (90) calendar days from the date of such attempted distribution. After such date, all Unclaime8 Property shall revert to the Liquidating Debtors automatically and without need for a further order b9 the Bankruptcy Court (notwithstanding any applicable federal, provincial, or state escheat, abandoneor unclaimed property laws to the contrary), and the Claim of any Holder to such property or Intere10 in property shall be forever barred. The Plan Administrator may implement reasonable attempts treach any recipient of an undeliverable distribution prior to reverting such property to the Liquidatin11 Debtors. 12 6. Minimum Distributions. 13 Notwithstanding any other provision of the Plan, in the Plan Administrator’s sole discretio14 the Plan Administrator will not be required to make distributions of Cash less than $25 in value, aneach such Claim to which this limitation applies shall be deemed fully and finally satisfied and n15 entitled to any further payment or consideration pursuant to Article IX and its Holder is forever barrepursuant to Article IX from asserting that Claim or Claims against the Debtors, the Liquidatin16 Debtors, their Estates, or their property. 17 7. Compliance With Tax Requirements. 18 (a) The Liquidating Debtors shall comply with all withholding and reporting requirement19 imposed by federal, state, or local taxing authorities in connection with making distributions pursuato the Plan. 20 (b) In connection with each distribution with respect to which the filing of an informatio21 return (such as an IRS Form 1099 or 1042) or withholding is required, the Liquidating Debtors shafile such information return with the IRS and provide any required statements in connection therewit22 to the recipients of such distribution, or effect any such withholding and deposit all moneys so withhel23 to the extent required by law. With respect to any Person from whom a tax identification numbecertified tax identification number or other tax information required by law to avoid withholding ha24 not been received, the Liquidating Debtors may, in their sole option, withhold the amount requireand distribute the balance to such Person or decline to make such distribution until the information i25 received. 26 8. Record Date in Respect to Distributions. 27 28

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1 Except as set forth below, the record date and time for the purpose of determining whicPersons are entitled to receive any and all distributions on account of any Allowed Claims or Interest2 irrespective of the date of or number of distributions, shall be the Record Date. 3 F. Litigation, Objections to Claims, and Determination of Taxes 4 1. Litigation. 5 Except as may be expressly provided otherwise in the Plan, the Liquidating Debtors, throug6 the Plan Administrator, shall be responsible for pursuing Retained Rights of Action, any objection tthe allowance of any Claim, and the determination of tax issues and liabilities. 7 2. Objections to Claims; Objection Deadline. 8 As of the Effective Date, the Liquidating Debtors shall have exclusive authority to fil9 objections, settle, compromise, withdraw or litigate to judgment objections to Claims. Any objectio10 to a Claim or Interest shall be filed with the Bankruptcy Court and served on the Person holding sucClaim or Interest within one hundred eighty (180) calendar days after the Effective Date (as may b11 extended pursuant to this section, the “Objection Deadline”), provided that the Liquidating Debtormay seek one or more extensions thereof subject to Bankruptcy Court approval and with notice onl12 to parties that have requested such notice pursuant to Bankruptcy Rule 2002. 13 3. Tax Determinations. 14 In addition to any other remedies or procedures available a) to dispute claims for taxes of ankind of the Debtors, whether pre-petition tax claims and/or administrative expense tax claims, b) t15 determine the amount of any tax that may be owed by any of the Debtors, whether pre-petition taxeor administrative expense taxes, or c) to seek recovery of refunds of taxes by any of the Debtor16 whether the refunds sought are pre-petition refunds or are post-petition refunds, the LiquidatinDebtors, at any time, may utilize (and receive the benefits of) section 505 of the Bankruptcy Code i17 order to: 18 (1) determine the amount of any tax liability of any of the Debtors or the Liquidating Debtorrelating to an act or event occurring prior to the Effective Date; 19 (2) object to any claim for taxes against any of the Debtors or the Liquidating Debtors relatinto an act or event occurring prior to the Effective Date; or 20 (3) determine the amount of any refund of taxes asserted by any of the Debtors or thLiquidating Debtors arising prior to the Effective Date. 21 The Liquidating Debtors shall be entitled to invoke all relevant provisions of Section 505 with 22 respect to any and all tax issues relating to the Liquidating Debtors and/or the Debtors. 23 4. Temporary or Permanent Resolution of Disputed Claims. 24 The Liquidating Debtors may request that the Bankruptcy Court estimate any contingent o25 unliquidated Disputed Claim pursuant to section 502(c) of the Bankruptcy Code, irrespective owhether any Person has previously objected to such Disputed Claim. The Bankruptcy Court will retai26 jurisdiction and power to estimate any contingent or unliquidated Disputed Claim at any time. If thBankruptcy Court estimates any contingent or unliquidated Disputed Claim, that estimated amou27 will constitute either the Allowed amount of such Disputed Claim or a maximum limitation on suc28 Disputed Claim, as determined by the Bankruptcy Court. If the estimated amount constitutes

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1 maximum limitation on such Disputed Claim, then the Liquidating Debtors may elect to pursue ansupplemental proceedings to object to any ultimate payment on account of such Disputed Claim. I2 addition, the Liquidating Debtors may resolve or adjudicate any Disputed Claim in the manner iwhich the amount of such Claim or Interest and the rights of the Holder of such Claim or Intere3 would have been resolved or adjudicated if the Chapter 11 Cases had not been commenced. All of th4 aforementioned objection, estimation and resolution procedures are cumulative and not necessarilexclusive of one another. 5 5. Setoffs. 6 The Liquidating Debtors may, but shall not be required to, setoff against any Claim, and th7 payments or other distributions to be made pursuant to the Plan in respect of such Claim may be setofagainst claims of any nature whatsoever that the Debtors or the Estates may have against the Holde8 of such Claim; provided, however, that neither the failure to do so nor the allowance of any Clai9 under the Plan shall constitute a waiver or release by the Liquidating Debtors of any such claim ththe Liquidating Debtors may have against such Holder, unless otherwise agreed to in writing by suc10 Holder and the Liquidating Debtors. 11 G. Injunctions, Exculpation, Releases and Related Provisions 12 1. Injunctions. 13 (a) Generally. 14 Unless otherwise provided in the Plan or the Confirmation Order, all injunctions and stay15 provided for in the Chapter 11 Cases pursuant to sections 105 and 362 of the Bankruptcy Code otherwise in effect on the Confirmation Date, shall remain in full force and effect until the Effectiv16 Date. From and after the Effective Date, all Persons are permanently enjoined from, and restraineagainst, commencing or continuing in any court any suit, action or other proceeding, or otherwis17 asserting any claim or interest, seeking to hold (i) the Liquidating Debtors or their Estates, or (ii) thproperty of the Debtors or their Estates, liable for any Claim, obligation, right, interest, debt or liabilit18 that has been released pursuant to the Plan. 19 (b) Non-Discharge of Debtors; Injunction. 20 In accordance with section 1141(d)(3) of the Bankruptcy Code, the Plan does n21 discharge the Debtors. Section 1141(c) of the Bankruptcy Code nevertheless provides, amonother things, that the property dealt with by the Plan is free and clear of all Claims and Interest22 against the Debtors. As such, no Person may receive any payment from, or seek recoursagainst, any assets that are to be distributed under the Plan other than assets required to b23 distributed to that Person under the Plan. As of the Effective Date, all parties are preclude24 from asserting against any property to be distributed under the Plan any Claims, rights, causeof action, liabilities, or Interests based upon any act, omission, transaction, or other activity tha25 occurred before the Effective Date except as expressly provided in the Plan or the ConfirmatioOrder. 26 2. Exculpation. 27 28 As of and subject to the occurrence of the Effective Date, for good and valuabl

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1 neither have nor incur any liability to any Person for any act taken or omitted to be taken, oor after the Petition Date, in connection with, or related to, the formulation, preparatio2 dissemination, implementation, administration, Confirmation or Consummation of the Plan oany contract, instrument, waiver, release or other agreement or document created or entere3 into, in connection with the Plan, or any other act taken or omitted to be taken in connectio4 with the Chapter 11 Cases or the Debtors up to and including the Effective Date; providehowever, that the foregoing provisions of this subsection shall have no effect on the liability 5 any Person that results from any such act or omission that is determined in a Final Order thave constituted willful misconduct or actual fraud. For the avoidance of doubt, the scope o6 the exculpation provided under Section 9.2 of the Plan does not include any of the current oformer members of the Debtors or any of the former directors, officers, managers an7 representatives of the Debtors who did not serve in such capacities during the Chapter 11 Case8 or a portion thereof. Notwithstanding anything in the Plan to the contrary, no Person servinas Plan Administrator shall have or incur any personal liability as the manager, member o9 officer of the Debtors or Liquidating Debtors for any act taken or omission made in connectiowith the wind-up or dissolution of the Liquidating Debtors or any nondebtor subsidiary o10 affiliate; provided, however, that the foregoing shall have no effect on the liability of the PlaAdministrator that results from any such act or omission that is determined in a Final Order t11 have constituted willful misconduct or actual fraud. 12 3. Debtor Release. 13 As of and subject to the occurrence of the Effective Date, for good and valuabl14 consideration, the Debtors, for themselves and the Estates, hereby irrevocably, unconditionalland generally release the Released Parties from any and all claims, obligations, rights, suit15 damages, causes of action, and liabilities, whether known or unknown, foreseen or unforeseeliquidated or unliquidated, fixed or contingent, matured or unmatured, in law or equity o16 otherwise, which the Debtors or their Estates ever had, now have or hereafter can, shall or ma17 have against any of the Released Parties from the beginning of time to the Effective Date that iany way relate to the Debtors, their direct or indirect non-Debtor subsidiaries, the Estates, o18 the Chapter 11 Cases; provided, however, that the foregoing provisions of Section 9.3 of the Plashall have no effect on the liability of any Person that results from any such act or omission th19 is determined in a Final Order to have constituted willful misconduct or actual fraud. For thavoidance of doubt, the scope of the release provided under Section 9.3 of the Plan does n20 include any of the current or former members of the Debtors or any of the former director21 officers, managers and representatives of the Debtors who did not serve in such capacities durinthe Chapter 11 Cases or a portion thereof. 22 4. Consenting Creditor Release. 23 As of and subject to the occurrence of the Effective Date and except for the treatmen24 provided in the Plan, for good and valuable consideration the Releasing Creditor, for itself an25 its respective present or former officers, directors, managers, shareholders, trustees, partnerand partnerships, members, agents, employees, representatives, attorneys, accountant26 professionals, and successors or assigns, in each case solely in their capacity as such, shall bdeemed to have completely, conclusively, unconditionally and irrevocably released the Release27 Debtor/Committee Parties from any and all claims, obligations, rights, suits, damages, causes action, and liabilities, whether known or unknown, foreseen or unforeseen, liquidated o28

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1 the Releasing Creditor, the Debtors or their Estates ever had, now have or hereafter can, shaor may have against any of the Released Debtor/Committee Parties from the beginning of tim2 to the Effective Date that in any way relate to the Debtors, their direct or indirect non-Debtosubsidiaries, the Estates, or the Chapter 11 Cases, provided, however, that the foregoing releas3 does not affect or impair any obligations under any intercreditor agreements or any othe4 agreements or arrangements between and among non-Debtor parties. For the avoidance odoubt, the Released Debtor/Committee Parties do not include any of the current or former no5 Debtor members of the Debtors or any former directors, officers, managers and representativeof the Debtors who did not serve in such capacities during the Chapter 11 Cases or a portio6 thereof. 7 VII. RISK FACTORS 8 A. The Plan Proponents May Not Be Able to Obtain Confirmation of the Plan 9 With regard to any proposed chapter 11 plan, the Plan Proponents may not receive the requisit10 acceptances to confirm a plan. In the event that votes from Claims in Classes entitled to vote arreceived in number and amount sufficient to enable the Bankruptcy Court to confirm the Plan, the Pla11 Proponents intend to seek Confirmation of the Plan by the Bankruptcy Court. If the requisitacceptances are not received, the Plan Proponents may nevertheless seek Confirmation of the Pla12 notwithstanding the dissent of certain Classes of Claims. The Bankruptcy Court may confirm the Pla13 pursuant to the “cramdown” provisions of the Bankruptcy Code, which allow the Bankruptcy Couto confirm a plan that has been rejected by an Impaired Class of Claims if it determines that the pla14 satisfies section 1129(b) of the Bankruptcy Code. To confirm a plan over the objection of a dissentinClass, the Bankruptcy Court also must find that at least one Impaired Class has accepted the plan, wit15 such acceptance being determined without including the acceptance of any “insider” in such Class. 16 Even if the requisite acceptances of a proposed plan are received, the Bankruptcy Court mignot confirm the Plan as proposed if the Bankruptcy Court finds that any of the statutory requirement17 for confirmation under section 1129 of the Bankruptcy Code have not been met. 18 If the Plan is not confirmed by the Bankruptcy Court, it is unclear whether the Plan Proponent19 would be able to successfully develop, prosecute, confirm and consummate an alternative plan that iacceptable to the Bankruptcy Court and the Debtors’ creditors, and what, if any, distributions Holder20 of Claims ultimately would receive with respect to their Claims. 21 B. Claims May Exceed the Plan Proponents’ Estimates 22 There is a risk under the Plan that Claims will materially exceed the Plan Proponent23 estimates, in which case distributions to Creditors would be significantly reduced or eliminateAmong other things, payments will only be made to Class 3 General Unsecured Creditors from N24 Distributable Estate Assets—in other words, after payment in full, or reserves for, all Plan Expenseand all administrative, priority, and secured Claims. The process of reconciling all such Claims ha25 not yet been completed and outstanding disputes remain that will need to be litigated or otherwisresolved. If and to the extent Plan Expenses and Allowed Administrative, Priority, and Secured Claim26 exceed the Plan Proponents’ estimates, amounts available for General Unsecured Creditors may b27 significantly reduced or eliminated. 28 C. The Conditions Precedent to the Effective Date of the Plan May Not Occur

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1 As more fully set forth in the Plan, the Effective Date is subject to several conditionprecedent. If such conditions precedent are not met or waived, the Effective Date will not occu2 Importantly, in the event the amount of the Refund Claim, coupled with the remaining Cash ohand does not exceed the aggregate of the amount of the Plan Expenses. Allowed Secure3 Claims, Allowed Administrative Expenses Claims, Allowed Priority Tax Claims and Allowe4 Non-Tax Priority Claims, and absent an agreement with the holder(s) of any of the foregoinClaims to receive less than payment in full on account of their Allowed Claim(s), the Effectiv5 Date will not occur and the Cases will in all likelihood convert to cases under Chapter 7 of thBankruptcy Code. 6 Specifically, the Debtors estimate that in a worst case scenario in which they fail t7 recover at least $3.0 million in connection with the Refund Claim, there will be insufficient cason hand to permit the Effective Date to occur. In such a circumstance, the Plan Proponent8 would likely seek to convert the Cases to cases under chapter 7 of the Bankruptcy Code. 9 In the event the Debtors recover at least $3.0 million in connection with the Refun10 Claim, through a combination of agreements with the holders of Administrative Claims and/othe amount of available Cash, it is likely that the Effective Date will occur. In the event th11 Debtors recover at least $4.5 million in connection with the Refund Claim, then it is likely thClass 3 General Unsecured Creditors will receive a distribution. 12 13 VIII. CONFIRMATION OF THE PLAN 14 A. The Confirmation Hearing 15 Section 1128(a) of the Bankruptcy Code requires the Bankruptcy Court, after notice, to hold hearing on Confirmation of the Plan. Section 1128(b) of the Bankruptcy Code provides that any part16 in interest may object to Confirmation of the Plan. 17 The Bankruptcy Court has scheduled the Confirmation Hearing to commence on July [DATE], 2021 at 2:00 p.m. [TIME] (prevailing Pacific Time), before the Honorable Mark S. Wallac18 United States Bankruptcy Judge, in the United States Bankruptcy Court for the Central District o19 California, Santa Ana Division. The Confirmation Hearing may be adjourned from time to timwithout further notice except for an announcement of the adjourned date made in the agenda for th20 Confirmation Hearing or at the Confirmation Hearing or any adjournment thereof. 21 Objections to Confirmation of the Plan must be filed and served so that they are actuallreceived by no later than June 9, [DATE], 2021 at 5:00 p.m.[TIME] (prevailing Pacific Time). Unles22 objections to Confirmation of the Plan are timely served and filed in compliance with th23 Disclosure Statement Order, they may not be considered by the Bankruptcy Court. 24 B. Requirements for Confirmation of the Plan 25 Among the requirements for the Confirmation of the Plan is that the Plan (i) is accepted by aImpaired Classes of Claims, or, if rejected by an Impaired Class of Claims, that the Plan “does n26 discriminate unfairly” and is “fair and equitable” as to such Impaired Class of Claims; (ii) is feasibland (iii) is in the “best interests” of Holders of Claims. 27 28 At the Confirmation Hearing, the Bankruptcy Court will determine whether the Plan satisfie

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1 Plan satisfies or will satisfy all of the necessary statutory requirements of chapter 11 of the BankruptcCode; (ii) the Plan Proponents have complied or will have complied with all of the necessar2 requirements of chapter 11 of the Bankruptcy Code; and (iii) the Plan has been proposed in good faitSpecifically, in addition to other applicable requirements, the Plan Proponents believe that the Pla3 satisfies or will satisfy the following applicable Confirmation requirements of section 1129 of th4 Bankruptcy Code: 5 • The Plan complies with the applicable provisions of the Bankruptcy Code. 6 • The Plan proponents have complied with the applicable provisions of the Bankruptcy Code. 7 • The Plan has been proposed in good faith and not by any means forbidden by law. 8 • Any payment made or promised under the Plan for services or for costs and expenses in, or iconnection with, the Chapter 11 Cases, or in connection with the Plan and incident to th9 Chapter 11 Cases, has been disclosed to the Bankruptcy Court, and any such paymen10 (1) made before the Confirmation of the Plan is reasonable; or (2) is subject to the approval othe Bankruptcy Court as reasonable, if it is to be fixed after Confirmation of the Plan. 11 • Either each Holder of a Claim in an Impaired Class of Claims has accepted the Plan, or wi12 receive or retain under the Plan on account of such Claim property of a value, as of the EffectivDate of the Plan, that is not less than the amount that such Holder would receive or retain 13 the Debtors were liquidated on the Effective Date of the Plan under chapter 7 of the Bankruptc14 Code. 15 • Each Class of Claims that is entitled to vote on the Plan will have accepted the Plan, or thPlan can be confirmed without the approval of a Class that did not accept the Plan pursuant t16 section 1129(b) of the Bankruptcy Code. 17 • Except to the extent a different treatment is agreed to, the Plan provides that all AlloweAdministrative Expenses, Allowed Priority Tax Claims and Allowed Priority Non-Tax Claim18 will be paid in full on the Effective Date, or as soon thereafter as is reasonably practicabl19 See the discussion below regarding the feasibility of the Plan. 20 • At least one Class of Impaired Claims will have accepted the Plan, determined withoincluding any acceptance of the Plan by any insider holding a Claim in that Class. 21 • Confirmation of the Plan is not likely to be followed by the liquidation or the need for furthe22 financial reorganization of the Debtors or any successors thereto. 23 • All accrued and unpaid fees of the type described in 28 U.S.C. § 1930, including the fees the U.S. Trustee, will be paid as of the Effective Date. 24 25 C. Best Interests of Creditors 26 Often called the “best interests of creditors” test, section 1129(a)(7) of the Bankruptcy Codrequires that a Bankruptcy Court find, as a condition to confirmation of a chapter 11 plan, that the pla27 provides, with respect to each impaired class, that each holder of a claim or an interest in such claseither (i) has accepted the plan or (ii) will receive or retain under the plan property of a value that i28

49

1 7 on the Effective Date. To make these findings, the Bankruptcy Court must: (a) estimate the casliquidation proceeds that a chapter 7 trustee would generate if each of the Debtors’ Chapter 11 Case2 were converted to a chapter 7 case on the Effective Date and the assets of the Debtors’ Estates werliquidated; (b) determine the liquidation distribution that each non-accepting Holder of a Claim or a3 Interest would receive from such liquidation proceeds under the priority scheme dictated in chapter 4 and (c) compare the Holder’s liquidation distribution to the distribution under the Plan that the Holdewould receive if the Plan were confirmed and consummated. 5 Here, the costs of liquidation under chapter 7 of the Bankruptcy Code would include th6 statutory fees payable to a chapter 7 trustee, and the fees that would be payable to additional attorneyand other professionals that such a trustee may engage (who would need time to understand cas7 issues), which amounts would have to be paid before anything is paid to Holders of Allowed GenerUnsecured Claims. 8 9 Conversion to chapter 7 of the Bankruptcy Code would also mean the establishment of a neclaims bar date, which could result in new General Unsecured Claims being asserted against th10 Estates, thereby diluting the recoveries of other Holders of Allowed General Unsecured Claims. 11 The following liquidation analysis chart demonstrates that the Holders of Claims will receivequal or greater value as of the Effective Date under the Plan than such Holders would receive in 12 chapter 7 liquidation: 13 Recovery % 14 Claim Liqu. Ch. 7 Ch. 11 15 $000s Amount Value Liqu.% Plan % 16 Cash on Hand (estimated as of Effective Date) 600 600 17 Deposits7 913 913 18 Allowed CDTFA Tax Refund8 638 5,000 19 Gross Proceeds Available for Distribution 2,151 6,513 20 Less Secured Claims 200 200 200 21 22 Less Chapter 7 Administrative Expenses 23 Ch. 7 Trustee Fees 138 138 100% N/A 24 Ch 7 Professional Fees 100 100 100% N/A 25 26 7 The gross amount of the deposits are estimated to total $2,153,870.19. The liquidation value excludes deposits which 27 the Debtors believe are not collectible and reflects a thirty percent (30%) reduction of the Debtors’ estimated remaining amount. 28 8

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1 Proceeds Available for Ch. 11 Administrative 1,713 6,313 Expenses 2 3 Less Chapter 11 Administrative Expenses 4 Ch. 11 Professional Fees 3,500 1061 30.3% 100% 5 Non-Professional Post-Petition Administrative 30.3% N/A Expense Claims (Ch. 7 scenario) 6 2,153 652 Non-Professional Post-Petition Administrative 753 N/A N/A 100% 7 Expense Claims (Ch. 11 scenario) 8 Chapter 11 Plan Expenses 300 N/A N/A 100% 9 Proceeds Available for Unsecured Claims 0 1,760 10 Less Unsecured Claims 11 Estimated Priority Unsecured Claims 1,000 1,000 0.00% 100% 12 Estimated General Unsecured Claims9 40,000 40,000 0.00% 0.5%-13 5% 14 For these reasons, among others, the Plan Proponents believe that Holders of Claims wi15 receive equal or greater value as of the Effective Date under the Plan than such Holders would receiv16 in a chapter 7 liquidation. 17 D. Feasibility 18 Section 1129(a)(11) of the Bankruptcy Code requires that confirmation of the plan is not likelto be followed by the liquidation, or the need for further financial reorganization of the Debtors, o19 any successor to the Debtors (unless such liquidation or reorganization is proposed in the plan). Apreviously discussed, the Bankruptcy Court has made a determination that it is more probable than n20 that the Debtors will obtain refunds in the approximate amounts set forth in the Estimation Motio21 and that CDTFA’s claims will also be limited as set forth in the Estimation Motion. As set forth ithe chart above, assuming at least $4.5 million is recovered in connection with the Refund Claim, th22 Plan should be able to go effective without the necessity of seeking the agreement of any holder of aAllowed Claim to receive treatment other than payment in full. 23 The Debtors believe they will recover in excess of $4.5 million in connection with the Refun24 Claims. If less than $4.5 million is recovered, but no less than $3.0 million,_ the Debtors believe the25 will be able to obtain the agreement (and already have the agreement in principle) from sufficieholders of Allowed Claims for alternative treatment under the Plan which would enable the Plan to g26 effective. However, it is unlikely that General Unsecured Claims in Class 3 will receive andistribution unless at least $4.5 million is recovered in connection with the Refund Claim. Howeve27 28 9

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1 there can be no assurance regarding the ultimate outcome of the Refund Claim. In the event that lesthan $3.0 million is recovered in connection with the Refund Claim, then the most likely outcome f2 these cases is that the Plan Proponents will seek to convert the Chapter 11 Cases to cases under chapt7 of the Bankruptcy Code. 3 E. Acceptance by Impaired Classes 4 5 The Bankruptcy Code requires, as a condition to confirmation, that, except as described in thfollowing section, each class of claims or interests that is impaired under a plan accept the plan. 6 class that is not “impaired” under a plan is deemed to have accepted the plan and, therefore, solicitatioof acceptances with respect to such class is not required. 7 A class is “impaired” unless a plan: (a) leaves unaltered the legal, equitable and contractu8 rights to which the claim or the interest entitles the holder of such claim or interest; or (b) cures andefault, reinstates the original terms of such obligation, compensates the holder for certain damage9 or losses, as applicable, and does not otherwise alter the legal, equitable or contractual rights to whic10 such claim or interest entitles the holder of such claim or interest. 11 Section 1126(c) of the Bankruptcy Code defines acceptance of a plan by a class of impaireclaims as acceptance by holders of at least two-thirds in dollar amount and more than one-half i12 number of allowed claims in that class, counting only those claims that actually voted to accept reject the plan. Thus, a Class of Impaired Claims will have voted to accept the Plan only if two-third13 in amount and a majority in number actually voting cast their Ballots in favor of acceptance. 14 F. Confirmation Without Acceptance by All Impaired Classes 15 Section 1129(b) of the Bankruptcy Code allows a Bankruptcy Court to confirm a plan even 16 all impaired classes have not accepted it, provided that the plan has been accepted by at least onimpaired class of claims, determined without including the acceptance of the plan by any inside17 Notwithstanding an impaired class’s rejection or deemed rejection of the plan, such plan will bconfirmed, at the plan proponent’s request, in a procedure commonly known as “cramdown,” so lon18 as the plan does not “discriminate unfairly” (as discussed below) and is “fair and equitable” (a19 discussed below) with respect to each class of claims or interests that is impaired under, and has naccepted, the plan. 20 To the extent that any Impaired Class rejects the Plan or is deemed to have rejected the Pla21 the Plan Proponents shall request Confirmation of the Plan under section 1129(b) of the BankruptcCode. The Plan Proponents reserve the right to alter, amend, modify, revoke, or withdraw the Pla22 the Plan Supplement, or any schedule or exhibit, including to amend or modify it to satisfy th23 requirements of section 1129(b) of the Bankruptcy Code, if necessary. 24 1. No Unfair Discrimination 25 The “unfair discrimination” test applies to classes of claims or interests that reject or ardeemed to have rejected a plan and that are of equal priority with another class of claims or interest26 that is receiving different treatment under such plan. The test does not require that the treatment osuch classes of claims or interests be the same or equivalent, but that such treatment be “fair.” I27 general, bankruptcy courts consider whether a plan discriminates unfairly in its treatment of classes 28 claims of equal rank (e.g., classes of the same legal character). Bankruptcy courts will take int

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1 account a number of factors in determining whether a plan discriminates unfairly, and, accordingly, plan could treat two classes of unsecured creditors differently without unfairly discriminating again2 either class. The Plan Proponents submit that if the Plan Proponents “cramdown” the Plan pursuato section 1129(b) of the Bankruptcy Code, the Plan is structured such that it does not “discriminat3 unfairly” against any rejecting Class. Nevertheless, there can be no assurance that the Bankruptc4 Court will reach the same conclusion. 5 2. Fair and Equitable Test 6 The “fair and equitable” test applies to classes that reject or are deemed to have rejected a plaand are of different priority and status vis-à-vis another class (e.g., secured versus unsecured claim7 or unsecured claims versus equity interests), and includes the general requirement that no class claims receive more than 100% of the amount of the allowed claims in such class, including interes8 As to the rejecting class, the test sets different standards depending upon the type of claims or interest9 in such rejecting class. The Plan Proponents submit that if the Plan Proponents “cramdown” the Plapursuant to section 1129(b) of the Bankruptcy Code, the Plan is structured such that the applicabl10 “fair and equitable” standards are met. 11 G. Alternatives to the Plan 12 The Plan Proponents believe that the Plan is in the best interests of Holders of Claims. Ihowever, the requisite acceptances of the voting Classes of Claims are not received, or no Plan i13 confirmed and consummated, the theoretical alternatives to the Plan include: (a) formulation of a14 alternative plan or plans of liquidation, or (b) liquidation of the Debtors under chapter 7 of thBankruptcy Code. 15 The Plan Proponents believe that the Plan enables Holders of Claims to realize the greate16 possible recovery under the circumstances, and, as compared to any alternative plan of liquidatiohas the greatest chance of being confirmed and consummated. 17 IX. CERTAIN UNITED STATES FEDERAL INCOME TAX CONSEQUENCES OF TH18 PLAN 19 The following discussion is a summary of certain U.S. federal income tax consequences of th20 Plan to Holders of Claims against the Debtors. This discussion is based on the Internal Revenue Cod(the “Tax Code”), Treasury Regulations promulgated and proposed thereunder, judicial decisions an21 published administrative rules and pronouncements of the Internal Revenue Service (“IRS”), all as ieffect on the date hereof. Due to the complexity of certain aspects of the Plan, the lack of applicabl22 legal precedent, the possibility of changes in the law, the differences in the nature of the Claim23 (including Claims within the same Class), the Holder’s status and method of accounting (includinHolders within the same Class) and the potential for disputes as to legal and factual matters with th24 IRS, the tax consequences described herein are subject to significant uncertainties. No legal opinionhave been requested from counsel with respect to any of the tax aspects of the Plan and no ruling25 have been or will be requested from the IRS with respect to the any of the issues discussed beloFurther, legislative, judicial or administrative changes may occur, perhaps with retroactive effec26 which could affect the accuracy of the statements and conclusions set forth below as well as the ta27 consequences to the Debtors and the Holders of Claims. 28

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1 This discussion does not purport to address all aspects of U.S. federal income taxation that mabe relevant to the Debtors or the Holders of Claims in light of their personal circumstances, nor doe2 the discussion deal with tax issues with respect to taxpayers subject to special treatment under the U. federal income tax laws (including, for example, banks, governmental authorities or agencies, pass3 through entities, brokers and dealers in securities, traders that mark-to-market their securities, mutu4 funds, insurance companies, other financial institutions, real estate investment trusts, tax-exemorganizations, small business investment companies, regulated investment companies, foreig5 taxpayers, persons whose functional currency is not the U.S. dollar, persons subject to the alternativminimum tax, and persons holding Claims or Interests as part of a “straddle,” “hedge,” “constructiv6 sale” or “conversion transaction” with other investments). This discussion does not address the taconsequences to Holders of Claims who did not acquire such Claims at the issue price on origin7 issue. No aspect of foreign, state, local or estate and gift taxation is addressed. 8 The U.S. federal income tax consequences of the distributions contemplated by the Plan to th9 Holders of Claims that are U.S. Persons will depend upon a number of factors. For purposes of thfollowing discussion, a “U.S. Person” is any person or entity (1) who is a citizen or resident of th10 United States, (2) that is a corporation or partnership created or organized in or under the laws of thUnited States or any state thereof, (3) that is an estate, the income of which is subject to U.S. feder11 income taxation regardless of its source or (4) that is a trust (a) the administration over which a Unite12 States person can exercise primary supervision and all of the substantial decisions of which one more U.S. persons have the authority to control; or (b) that has in effect a valid election to continue t13 be treated as a U.S. Person for U.S. federal income tax purposes. In the case of a partnership, the tatreatment of its partners will depend on the status of the partner and the activities of the partnershi14 U.S. Persons who are partners in a partnership should consult their tax advisors. A “Non-U.S. Personis any person or entity that is not a U.S. Person. For purposes of the following discussion and unles15 otherwise noted below, the term “Holder” will mean a Holder of a Claim that is a U.S. Person. 16 Except where otherwise indicated, this discussion assumes that the Claims are held as capit17 assets within the meaning of section 1221 of the Tax Code. 18 THE FOLLOWING SUMMARY IS NOT INTENDED TO CONSTITUTE ADVICE TANY PARTY, AND IS NOT A SUBSTITUTE FOR CAREFUL TAX PLANNING AND ADVIC19 BASED UPON THE PERSONAL CIRCUMSTANCES OF EACH HOLDER OF A CLAIM. EACHOLDER OF A CLAIM, AS WELL AS EACH HOLDER OF AN INTEREST, IS URGED T20 CONSULT WITH SUCH HOLDER’S TAX ADVISORS CONCERNING THE U.S. FEDERA21 STATE, LOCAL, FOREIGN AND OTHER TAX CONSEQUENCES APPLICABLE UNDER THPLAN. 22 IRS Circular 230 Notice. To ensure compliance with IRS Circular 230, Holders of Claim23 and Interests are hereby notified that: (a) any discussion of federal tax issues contained or referreto in this Disclosure Statement is not intended or written to be used, and cannot be used, by Holder24 of Claims and Interests for the purpose of avoiding penalties that may be imposed on them unde25 the Tax Code; (b) such discussion is written in connection with the promotion or marketing by thDebtors of the transactions or matters addressed herein; and (c) Holders of Claims and Interest26 should seek advice based on their particular circumstances from an independent tax advisor. 27 A. Federal Taxation Issues Related to Pass-Through Entities in General 28

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1 For U.S. federal income tax law purposes, an entity can be organized as a corporation, partnership, or a hybrid entity (otherwise known as S corporations and limited liability companies2 The two primary differences between corporations and partnerships are how the entity’s earnings artaxed and whether or not the shareholder/owners are shielded from the liabilities of the entit3 Generally, corporations are treated as independent tax-paying entities, unaffected by the person4 characteristics of their shareholders or changes in their composition as a result of transfers of stocfrom old shareholders to new ones, giving rise to the potential for double taxation. Becaus5 corporations are treated independently, corporate income is taxed to a corporation as it is received accrued, and is taxed at the shareholder level when and if the corporation distributes earnings to th6 shareholders or they sell their stock. Partnerships, however, are not entities subject to income taInstead, the partners are taxed directly on partnership income whether or not it is actually distribute7 to them. 8 Hybrid entities, on the other hand, combine the two primary differences between corporation9 and partnerships. As to S corporations, shareholders are shielded from entity level liability similar tthat of a corporation; however, generally, the earnings of the entity are taxed at the ownership lev10 similar to that of a partnership. As to limited liability companies, member-owners are shielded froentity level liability similar to that of a corporation; however, unique to the LLC, an option exists t11 be taxed as a corporation or taxed as a partnership, provided that the LLC has at least two membe12 owners, as set forth under Treasury Regulations Section 301.7701-3. 13 Generally, pass-through entities are subject to a single layer of tax on their earnings at thownership level (partner, member, or shareholder depending on entity type). Taxable income of pas14 through entities is computed at the entity level (generally each type of entity will file a tax returshowing no tax liability at the entity level); however, each owner is taxed separately on his, her, or it15 distributive share of income, gain, loss, deduction, and/or credit, as applicable. The character of thitems included in taxable income is determined at the entity level with no regard to the owners16 individual characteristics. With respect to tax attributes, pass-through entities are generally n17 allowed to maintain certain tax attributes, such as net operating losses, given such entities are ndirectly taxable. These tax attributes pass-through to the owners, and usage, carryback, 18 carryforward of these attributes is determined at the ownership level. 19 BECAUSE THE FINAL TAX TREATMENT OUTCOME DEPENDS ON EACH PARTY’SPECIFIC SITUATION, PARTIES IN INTEREST ARE URGED TO CONSULT WITH THEI20 TAX ADVISORS REGARDING THE TAX IMPLICATIONS TO THEM WITH RESPECT TO TH21 TRANSACTIONS CONTEMPLATED UNDER OR IN CONNECTION WITH THE PLAN ANTHEIR SPECIFIC SITUATION, AND NOTHING HEREIN IS INTENDED TO CONSTITUT22 ADVICE TO ANY PARTY. 23 B. Consequences to Creditors 24 1. Holders of Claims 25 Generally, a holder of a Claim should in most, but not all circumstances, recognize gain or los26 equal to the difference between the “amount realized” by such holder in exchange for its Claim ansuch holder’s adjusted tax basis in the Claim. The “amount realized” is equal to the sum of the cas27 and the fair market value of any other consideration received under a plan of reorganization in respeof a holder’s Claim. The tax basis of a holder in a Claim will generally be equal to the holder’s co28 therefore. To the extent applicable, the character of any recognized gain or loss (e.g., ordinary incom

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1 or short-term or long-term capital gain or loss) will depend upon the status of the holder, the nature the Claim in the holder’s hands, the purpose and circumstances of its acquisition, the holder’s holdin2 period of the Claim, and the extent to which the holder previously claimed a deduction for thworthlessness of all or a portion of the Claim. Generally, if the Claim is a capital asset in the holder’3 hands, any gain or loss realized will generally be characterized as capital gain or loss, and wi4 constitute long-term capital gain or loss if the holder has held such Claim for more than one year. 5 A Holder who received Cash in satisfaction of its Claims may recognize ordinary income oloss to the extent that any portion of such consideration is characterized as accrued interest. A Holde6 who did not previously include in income accrued but unpaid interest attributable to its Claim, anwho receives a distribution on account of its Claim pursuant to the Plan, will be treated as havin7 received interest income to the extent that any consideration received is characterized for United Statefederal income tax purposes as interest, regardless of whether such Holder realizes an overall gain o8 loss as a result of surrendering its Claim. A Holder who previously included in its income accrued b9 unpaid interest attributable to its Claim should recognize an ordinary loss to the extent that sucaccrued but unpaid interest is not satisfied, regardless of whether such Holder realizes an overall gai10 or loss as a result of the distribution it may receive under the Plan on account of its Claim. 11 Under the Plan, certain Creditors may receive only a partial distribution of their AlloweClaims. Whether the Holder of such Claims will recognize a loss or any other tax treatment wi12 depend upon facts and circumstances that are specific to the nature of the Holder and its Claim13 Creditors should consult their own tax advisors. 14 2. Non-United States Persons 15 A Holder of a Claim that is a Non-U.S. Person generally will not be subject to United Statefederal income tax with respect to property (including money) received in exchange for such Clai16 pursuant to the Plan, unless (i) such Holder is engaged in a trade or business in the United States twhich income, gain or loss from the exchange is “effectively connected” for United States feder17 income tax purposes, or (ii) if such Holder is an individual, such Holder is present in the United State18 for 183 days or more during the taxable year of the exchange and certain other requirements are met19 C. Importance of Obtaining Professional Tax Assistance 20 THE FOREGOING DISCUSSION IS INTENDED ONLY AS A SUMMARY OF CERTAIINCOME TAX CONSEQUENCES OF THE PLAN AND IS NOT A SUBSTITUTE FOR CAREFU21 TAX PLANNING WITH A TAX PROFESSIONAL. THE ABOVE DISCUSSION IS FOINFORMATIONAL PURPOSES ONLY AND IS NOT TAX ADVICE. THE TA22 CONSEQUENCES ARE IN MANY CASES UNCERTAIN AND MAY VARY DEPENDING O23 A CLAIM HOLDER’S OR INTEREST HOLDER’S PARTICULAR CIRCUMSTANCEACCORDINGLY, CLAIM AND INTEREST HOLDERS ARE URGED TO CONSULT THEI24 TAX ADVISORS ABOUT THE UNITED STATES FEDERAL, STATE AND LOCAL, ANAPPLICABLE FOREIGN INCOME AND OTHER TAX CONSEQUENCES OF THE PLAN.] 25 26 27 28

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1 2 X. RECOMMENDATION 3 In the opinion of the Plan Proponents, the Plan is superior and preferable to the alternativedescribed in this Disclosure Statement. Accordingly, the Plan Proponents recommend that Holders 4 Claims entitled to vote on the Plan vote to accept the Plan and support Confirmation of the Plan. 5 6 April May ___, 2021 7 Brad Smith, CRO of Debtors and Debtors in Possession 8 9 10 11 May ____, 2021 [________________] Authorized Representative of 12 Official Committee of Unsecured Creditors 13 14 Prepared by: 15 Debtors’ Counsel 16 Alan J. Friedman (Bar No. 132580) 17 SHULMAN BASTIAN FRIEDMAN & BUI LLP 100 Spectrum Center Drive, Suite 600 18 Irvine, California 92618 Telephone: (949) 340-3400 19 Facsimile: (949) 340-3000 Email: afriedman@shulmanbastian.com 20 -and- 21 Committee Counsel 22 Robert J. Feinstein (Pro Hac Vice) 23 Alan J. Kornfeld (Bar No. 130063) Jeffrey W. Dulberg (Bar No. 181200) 24 PACHULSKI STANG ZIEHL & JONES LLP 10100 Santa Monica Blvd., 13th Floor 25 Los Angeles, CA 90067 Telephone: (310) 277-6910 26 Facsimile: (310) 201-0760 Email: rfeinstein@pszjlaw.com 27 akornfeld@pszjlaw.com jdulberg@pszjlaw.com 28

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1 EXHIBIT A 2 Joint Plan of Liquidation 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 EXHIBIT B 2 Organizational Chart 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 PROOF OF SERVICE OF DOCUMENT 2 I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is 100 Spectrum Center Drive, Suite 600, Irvine, CA 92618. 3 A true and correct copy of the foregoing document entitled (specify): SECOND AMENDED DISCLOSURE 4 STATEMENT FOR SECOND AMENDED JOINT CHAPTER 11 PLAN OF LIQUIDATION PROPOSED BY DEBTORS AND OFFICIAL COMMITTEE OF UNSECURED CREDITORS, AS MODIFIED [REDLINED 5 VERSION] will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: 6 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to 7 controlling General Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) May 6, 2021 I checked the CM/ECF docket for this bankruptcy case 8 or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List toreceive NEF transmission at the email addresses stated below: 9 10 Service information continued on attached pag 11 2. SERVED BY UNITED STATES MAIL: On (date) May 6, 2021 , I served the following persons and/or entities at the last known addresses in this12 bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelopein the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here13 constitutes a declaration that mailing to the judge will be completed no later than 24 hours after thedocument is filed. 14 The Honorable Mark S. Wallace Office of the United States Trustee 15 U.S. Bankruptcy Court 411 West Fourth Street Ronald Reagan Federal Building Suite 7160 16 411 W. Fourth Street, Suite 6135 Santa Ana, CA 92701 Santa Ana, CA 92701 17 Service information continued on attached pag 18 3.SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL19 (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on(date) , I served the following persons and/or entities by personal delivery, overnight 20 mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or 21 overnight mail to, the judge will be completed no later than 24 hours after the document is filed. 22 Service information continued on attached pag 23 I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 24 25 May 6, 2021 Lori Gauthier /s/ Lori Gauthier 26 Date Printed Name Signature 27

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1 ADDITIONAL SERVICE INFORMATION (if needed): 2 1. SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”)3 • Jonathan T Amitrano jamitrano@taylorlaw.com, ltaylor@taylorlaw.com,ecf@taylorlaw.com• Kyra E Andrassy kandrassy@swelawfirm.com, 4 lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com• David M Banker dbanker@lowenstein.com, dbanker@lowenstein.com5 • Richard L Barnett rick@barnettrubin.com, kelly@barnettrubin.com• James Cornell Behrens jbehrens@milbank.com, 6 gbray@milbank.com;mshinderman@milbank.com;dodonnell@milbank.com;jbrewster@milbank. om;JWeber@milbank.com 7 • Shraddha Bharatia notices@becket-lee.com 8 • Matthew Bouslog MBouslog@gibsondunn.com, jsprecher@gibsondunn.com• J Scott Bovitz bovitz@bovitz-spitzer.com 9 • Larry Butler notices@becket-lee.com • Frank Cadigan frank.cadigan@usdoj.gov 10 • Andrew W Caine acaine@pszjlaw.com • David Cantrell dcantrell@lc-law-llp.com 11 • Jeffrey D Cawdrey jcawdrey@grsm.com, madeyemo@gordonrees.com;sdurazo@grsm.com• Conrad K Chiu cchiu@pryorcashman.com 12 • Shawn M Christianson cmcintire@buchalter.com, schristianson@buchalter.com• Theodore A Cohen tcohen@sheppardmullin.com, amontoya@sheppardmullin.com13 • Erinn M Contreras econtreras@sheppardmullin.com, nsaucedo@sheppardmullin.com• Joseph Corrigan Bankruptcy2@ironmountain.com 14 • Raphael Cung rcung@callahan-law.com, jeggleston@callahan-law.com;deisenbrey@callahan-law.com;mmartinez@callahan-law.com 15 • J.D. Cuzzolina info@cuzzlaw.com, jp@cuzzlaw.com • Michael T Delaney mdelaney@bakerlaw.com, TBreeden@bakerlaw.com16 • Jessica DiFrancesco notices@becket-lee.com • Caroline Djang caroline.djang@bbklaw.com, 17 laurie.verstegen@bbklaw.com;wilma.escalante@bbklaw.com 18 • Jeffrey W Dulberg jdulberg@pszjlaw.com • Robert J Feinstein rfeinstein@pszjlaw.com 19 • Scott D Fink colcaecf@weltman.com • Marc C Forsythe kmurphy@goeforlaw.com, mforsythe@goeforlaw.com;goeforecf@gmail.co20 • Alan J Friedman afriedman@shulmanbastian.com, lgauthier@shulmanbastian.com• Matthew T Furton mfurton@lockelord.com, 21 Donna.Mathis@lockelord.com;autodocket@lockelord.com • Thomas M Gaa tgaa@bbslaw.com 22 • Beth Gaschen bgaschen@wgllp.com, kadele@wgllp.com;cbmeeker@gmail.com;cyoshonis@wgllp.com;lbracken@wgllp.com;bgaschen23 @ecf.courtdrive.com • Nancy S Goldenberg nancy.goldenberg@usdoj.gov 24 • David B Golubchik dbg@lnbyb.com, stephanie@lnbyb.com • Christopher J Green chrisgreen@ucla.edu, chrisgreen@ucla.edu;christopher-green-25 2815@ecf.pacerpro.com • Justin D Harris jdh@harrislawfirm.net, felicia@harrislawfirm.net26 • Michael J Hauser michael.hauser@usdoj.gov • Eric M Heller eric.m.heller@irscounsel.treas.gov 27 • Lydia A Hewett lydia.hewett@cpa.state.tx.usjoan.huh@cdtfa.ca.gov

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1 • Lillian Jordan ENOTICES@DONLINRECANO.COM, RMAPA@DONLINRECANO.COM• Samuel M Kidder skidder@ktbslaw.com 2 • Rika Kido rkido@shulmanbastian.com, avernon@shulmanbastian.com• Jeannie Kim jkim@buchalter.com, dgatmen@sheppardmullin.com3 • Alan M Kindred akindred@leechtishman.com, alankindred@hotmail.com;dtomko@leechtishman.com;challer@leechtishman.com4 • Armand R. Kizirian armand@kizirianlaw.com, armand@boyamianlaw.com;michael@boyamianlaw.com;narine@boyamianlaw.com5 • Stuart I Koenig Skoenig@leechtishman.com, sfrey@leechtishman.com;jabrams@leechtishman.com 6 • Alan J Kornfeld akornfeld@pszjlaw.com, mdj@pszjlaw.com• Matthew J Kraus mkraus@lc-lawyers.com, mbuchheit@lc-lawyers.com7 • Jeffrey C Krause jkrause@gibsondunn.com, dtrujillo@gibsondunn.com;jstern@gibsondunn.com 8 • Donny P Le Donny.Le@doj.ca.gov 9 • Yochun Katie Lee kylee@akingump.com, tsouthwell@akingump.com;westdocketing@akingump.com 10 • Elan S Levey elan.levey@usdoj.gov, tiffany.davenport@usdoj.gov• William N Lobel wlobel@tocounsel.com, jokeefe@tocounsel.com;sschuster@tocounsel.com11 • Aaron J Malo amalo@sheppardmullin.com, jsummers@sheppardmullin.com• Robert S Marticello Rmarticello@swelawfirm.com, 12 gcruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com• Ashley M McDow amcdow@foley.com, sgaeta@foley.com;smoses@foley.com13 • David W. Meadows david@davidwmeadowslaw.com • Reed M Mercado rmercado@sheppardmullin.com 14 • Harlene Miller harlene@harlenemillerlaw.com, harlenejd@gmail.com• Raymond F Moats colcaecf@weltman.com 15 • Elizabeth L Musser elizabeth.musser@clydeco.us • Jeffrey P Nolan jnolan@pszjlaw.com 16 • Courtney E Norton cnorton@greenbergglusker.com, kwoodson@greenbergglusker.com;jking@greenbergglusker.com;calendar@greenbergglusker.co17 • Ryan D O'Dea rodea@shulmanbastian.com, LGauthier@shulmanbastian.com• John M O'Donnell john.o'donnell@ftb.ca.gov, Martha.Gehrig@ftb.ca.gov18 • Ernie Zachary Park ernie.park@bewleylaw.com 19 • Ronak N Patel rpatel@rivco.org, dresparza@rivco.org;mdominguez@rivco.org• Mary A Petrovic petrovic.mary@pbgc.gov, efile@pbgc.gov20 • Marc S Pfeuffer pfeuffer.marc@pbgc.gov, efile@pbgc.gov• Kathy Bazoian Phelps kphelps@diamondmccarthy.com, helen.choi@diamondmccarthy.com21 • Christopher E Prince , jmack@lesnickprince.com;cprince@ecf.courtdrive.com;jnavarro@lesnickprince.com22 • Amelia Puertas-Samara itcdbgc@edd.ca.gov, itcdgc@edd.ca.gov• Christopher B Queally cqueally@callahan-law.com, jluirette@callahan-law.com23 • Michael B Reynolds mreynolds@swlaw.com, kcollins@swlaw.com• Todd C. Ringstad becky@ringstadlaw.com, arlene@ringstadlaw.com24 • Christopher O Rivas crivas@reedsmith.com, chris-rivas-8658@ecf.pacerpro.com• Jeremy E Rosenthal jrosenthal@sidley.com 25 • Joel W Ruderman ruderman.joel@pbgc.gov, email@pbgc.gov• Peter J Rudinskas pjr.legal@gmail.com 26 • James M Sabovich jsabovich@callahan-law.com, ksalour@callahan-law.com;jkirwin@callahan-law.com;rcung@callahan-law.com;bmccormack@callahan-27 law.com;erichards@callahan-law.com;SRobinson@callahan-law.com• Jonathan C Sandler jsandler@bhfs.com, pherron@bhfs.com;sgrisham@bhfs.com

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1 • Daren M Schlecter daren@schlecterlaw.com, assistant@schlecterlaw.com• George E Schulman GSchulman@DanningGill.Com, 2 danninggill@gmail.com;gschulman@ecf.inforuptcy.com • Leonard M Shulman lshulman@shulmanbastian.com 3 • Donald W Sieveke , dws4law@pacbell.net • Donald W Sieveke ibmoola@yahoo.com, dws4law@pacbell.net4 • David A Smyth smythlaw@gmail.com, dsmyth2_@hotmail.com• Alex E Spjute spjute@hugheshubbard.com, gaurav.reddy@hugheshubbard.com5 • Sarah Stuppi Sarah@stuppilaw.com • Charles Tsai CHARLES.TSAI@DOJ.CA.GOV 6 • Helena Tseregounis helena.tseregounis@lw.com • United States Trustee (SA) ustpregion16.sa.ecf@usdoj.gov7 • Daniel Uribe duribe@gmail.com • Elissa A Wagner ewagner@pszjlaw.com 8 • Michael A Wallin mwallin@wallinrussell.com 9 • Michael J. Weiland mweiland@wgllp.com, kadele@wgllp.com;vrosales@wgllp.com;cbmeeker@gmail.com;lbracken@wgllp.com10 • Scott S Weltman colcaecf@weltman.com • Johnny White JWhite@wrslawyers.com, 11 aparisi@wrslawyers.com;eweiman@wrslawyers.com;chamilton@wrslawyers.com• Brandon J Witkow bw@witkowlaw.com, tg@witkowlaw.com 12 • Steven D Zansberg zansbergs@ballardspahr.com, DocketClerk_Denver@ballardspahr.com13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

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