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Full title: Certification of Counsel Regarding Proposed Findings of Fact, Conclusions of Law, and Order Confirming the Second Amended Joint Chapter 11 Plan for Klausner Lumber One LLC (related document(s)917, 1000, 1004, 1005) Filed by Klausner Lumber One LLC. (Attachments: # 1 Exhibit 1 # 2 Exhibit 2) (Butz, Daniel) (Entered: 06/30/2021)

Document posted on Jun 29, 2021 in the bankruptcy, 2 pages and 0 tables.

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KLAUSNER LUMBER ONE LLC, Debtor.1 Re: D.I. 917, 1000, 1004, 1005 CERTIFICATION OF COUNSEL REGARDING PROPOSED FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER CONFIRMING THE SECOND AMENDED JOINT CHAPTER 11 PLAN FOR KLAUSNER LUMBEREstablishing Procedures for the Solicitation and Tabulation of Votes to Accept or Reject the Joint Plan Proposed by the Debtor and the Official Committee of Unsecured Creditors, (III) Approving the Form of Ballot and Solicitation Materials, (IV) Establishing the Voting Record Date, (V) Fixing the Date, Time, and Place for the Confirmation Hearing and the Deadline for Filing Objections Pursuant to the Disclosure Statement Order, objections to confirmation of the Debtor’s Second Amended Joint Chapter 11 Plan for Klausner Lumber One LLC Proposed by the Debtor and the Official Committee of Unsecured Creditors (D.I. 1004) (the “Plan”) were due by June 24, 2021, at 4:00 p.m. 3. Prior to the deadline, the United States filed the Objection by the United States to the First Amended Joint Chapter 11 Plan for Klausner Lumber One LLC (D.I. 994) (the “USA Objection”), objecting to confirmation of the Plan unless certain modifications requested by the United States on behalf of the Internal Revenue Service were made.All other informal comments or objections to confirmation of the Plan were resolved prior to the noticed objection deadline and included in the form of proposed Plan filed at D.I. 1004 and the form of proposed Findings of Fact, Conclusions of Law, and Order Confirming the Second 1

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE Chapter 11 In re Case No. 20-11033 (KBO) KLAUSNER LUMBER ONE LLC, Debtor.1 Re: D.I. 917, 1000, 1004, 1005 CERTIFICATION OF COUNSEL REGARDING PROPOSED FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER CONFIRMING THE SECOND AMENDED JOINT CHAPTER 11 PLAN FOR KLAUSNER LUMBER ONE LLC The undersigned counsel to the above-captioned debtor and debtor in possession (the “Debtor”) hereby certifies as follows: 1. On May 20, 2021, the Court entered the Order (I) Approving the Disclosure Statement, (II) Establishing Procedures for the Solicitation and Tabulation of Votes to Accept or Reject the Joint Plan Proposed by the Debtor and the Official Committee of Unsecured Creditors, (III) Approving the Form of Ballot and Solicitation Materials, (IV) Establishing the Voting Record Date, (V) Fixing the Date, Time, and Place for the Confirmation Hearing and the Deadline for Filing Objections Thereto, and (VI) Approving Related Notice Procedures (D.I. 917) (the “Disclosure Statement Order”). 2. Pursuant to the Disclosure Statement Order, objections to confirmation of the Debtor’s Second Amended Joint Chapter 11 Plan for Klausner Lumber One LLC Proposed by the Debtor and the Official Committee of Unsecured Creditors (D.I. 1004) (the “Plan”) were due by June 24, 2021, at 4:00 p.m. 3. Prior to the deadline, the United States filed the Objection by the United States to the First Amended Joint Chapter 11 Plan for Klausner Lumber One LLC (D.I. 994) (the “USA Objection”), objecting to confirmation of the Plan unless certain modifications requested by the United States on behalf of the Internal Revenue Service were made. 4. The USA Objection was the only objection received to confirmation of the Plan. All other informal comments or objections to confirmation of the Plan were resolved prior to the noticed objection deadline and included in the form of proposed Plan filed at D.I. 1004 and the form of proposed Findings of Fact, Conclusions of Law, and Order Confirming the Second 1 The last four digits of the Debtor's federal tax identification number are 9109. The Debtor’s mailing address is Klausner Lumber One LLC, P.O. Box 878 Middleburg, VA 20118.

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Amended Joint Chapter 11 Plan for Klausner Lumber One LLC (the “Confirmation Order”) filed at D.I. 1005. 5. The further revised Confirmation Order, attached here to Exhibit 1, includes revised language resolving the USA Objection. The attorney for the United States has reviewed this Confirmation Order and confirmed that it resolves the USA Objection. 6. Attached hereto as Exhibit 2 is a redline of the further revised Confirmation Order comparing it to the version filed at D.I. 1005. WHEREFORE, the Debtor respectfully requests that the Court enter the Confirmation Order substantially in the form attached hereto as Exhibit 1 at the hearing currently scheduled for July 1, 2021 at 9:30 a.m. (ET). Dated: June 30, 2021 MORRIS, NICHOLS, ARSHT & TUNNELL LLP Wilmington, Delaware /s/ Daniel B. Butz Robert J. Dehney (No. 3578) Eric D. Schwartz (No. 3134) Daniel B. Butz (Bar No. 4227) 1201 North Market Street, 16th Floor P.O. Box 1347 Wilmington, Delaware 19899-1347 Telephone: (302) 658-9200 Facsimile: (302) 658-3989 Email: dbutz@mnat.com namer@mnat.com - and - WESTERMAN BALL EDERER MILLER ZUCKER & SHARFSTEIN, LLP Thomas A. Draghi (admitted pro hac vice) Alison M. Ladd (admitted pro hac vice) 1201 RXR Plaza Uniondale, NY 11556 Tel: 516-622-9200 tdraghi@westermanllp.com aladd@westermanllp.com Counsel for Debtor and Debtor in Possession

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