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Full title: Certificate of No Objection Regarding Joint Motion Pursuant to Section 105 of the Bankruptcy Code and Bankruptcy Rules 9109 and 7023 for an Order (i) Certifying a Class for Settlement Purposes, (ii) Appointing Plaintiff Helmut Thomay as Class Representative and Plaintiffs Counsel as Class Counsel, (iii) Preliminarily Approving Settlement, (iv) Approving Class Notice, and (v) Scheduling Fairness Hearing Filed by Klausner Lumber One LLC. (Amer, Nader) (Entered: 04/12/2021)

Document posted on Apr 11, 2021 in the bankruptcy, 2 pages and 0 tables.

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CERTIFICATE OF NO OBJECTION REGARDING JOINT MOTION PURSUANT TO SECTION 105 OF THE BANKRUPTCY CODE AND BANKRUPTCY RULES 9019 AND 7023 FOR AN ORDER (I) CERTIFYING A CLASS FOR SETTLEMENT PURPOSES, (II) APPOINTING PLAINTIFF HELMUT THOMAY AS CLASS REPRESENTATIVE AND PLAINTIFFS’ COUNSELThe undersigned hereby certifies that, as of the date hereof, Morris, Nichols, Arsht & Tunnell LLP (“Morris Nichols”) has received no answer, objection or other responsive pleading to the Joint Motion Pursuant to Section 105 of the Bankruptcy Code and Bankruptcy Rules 9109 and 7023 for an Order (i) Certifying a Class for Settlement Purposes, (ii) Appointing Plaintiff The undersigned further certifies that Morris Nichols has caused the review of the Court’s docket in this case and that no answer, objection or other responsive pleading to the Motion appears thereon.Pursuant to the notice of Motion, objections to the Motion were to be filed and served no later than March 22, 2021 at 4:00 pm (ET)WHEREFORE, the Debtor respectfully requests that the Order attached to the Motion be entered at the earliest convenience of the Court.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
Table 1 on page 1. Back to List of Tables
In re:
KLAUSNER LUMBER ONE LLC
Debtor.
HELMUT THOMAY and CORNELIUS
TURNER, on behalf of themselves and all others
similarly situated,
Plaintiffs,
v.
KLAUSNER LUMBER ONE LLC, KLAUSNER
LUMBER TWO LLC, KLAUSNER HOLDING
USA, INC., and KLAUSNER TRADING USA,
INC.,
Defendants.
CERTIFICATE OF NO OBJECTION REGARDING JOINT MOTION PURSUANT TO SECTION 105 OF THE BANKRUPTCY CODE AND BANKRUPTCY RULES 9019 AND 7023 FOR AN ORDER (I) CERTIFYING A CLASS FOR SETTLEMENT PURPOSES, (II) APPOINTING PLAINTIFF HELMUT THOMAY AS CLASS REPRESENTATIVE AND PLAINTIFFS’ COUNSEL AS CLASS COUNSEL, (III) PRELIMINARILY APPROVING SETTLEMENT, (IV) APPROVING CLASS NOTICE, AND (V) SCHEDULING FAIRNESS HEARING The undersigned hereby certifies that, as of the date hereof, Morris, Nichols, Arsht & Tunnell LLP (“Morris Nichols”) has received no answer, objection or other responsive pleading to the Joint Motion Pursuant to Section 105 of the Bankruptcy Code and Bankruptcy Rules 9109 and 7023 for an Order (i) Certifying a Class for Settlement Purposes, (ii) Appointing Plaintiff Helmut Thomay as Class Representative and Plaintiffs’’ Counsel as Class Counsel, (iii)

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Preliminarily Approving Settlement, (iv) Approving Class Notice, and (v) Scheduling Fairness Hearing (D.I. 766, Adv. D.I. 60) (the “Motion”), filed on March 8, 2021. The undersigned further certifies that Morris Nichols has caused the review of the Court’s docket in this case and that no answer, objection or other responsive pleading to the Motion appears thereon. Pursuant to the notice of Motion, objections to the Motion were to be filed and served no later than March 22, 2021 at 4:00 pm (ET) (the “Objection Deadline”). WHEREFORE, the Debtor respectfully requests that the Order attached to the Motion be entered at the earliest convenience of the Court. Dated: April 12, 2021 MORRIS, NICHOLS, ARSHT & TUNNELL LLP Wilmington, Delaware /s/ Nader A. Amer Robert J. Dehney (No. 3578) Eric D. Schwartz (No. 3134) Daniel B. Butz (Bar No. 4227) Nader A. Amer (Bar No. 6635) 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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