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Full title: Omnibus Objection to Claims /Debtors Sixth Omnibus Objection (Substantive) to Certain Claims Pursuant to 11 U.S.C. § 502, Fed. R. Bankr. P. 3007 and Del. L.R. 3007-1 (Disallow; Reduce and Allow). Filed by Bankruptcy Conflicts Counsel and Labor/ERISA Counsel for Debtor and Debtor in Possession. Hearing scheduled for 5/20/2021 at 10:00 AM at US Bankruptcy Court, 824 Market St., 6th Fl., Courtroom #3, Wilmington, Delaware. Objections due by 5/13/2021. (Attachments: # 1 Notice # 2 Exhibit 1 (Freeman Declaration) # 3 Exhibit 2 (Proposed Form of Order with Exhibits)) (Kotler, Lawrence) (Entered: 04/20/2021)

Document posted on Apr 19, 2021 in the bankruptcy, 9 pages and 0 tables.

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On August 26, 2020, the Court entered the Order (I) Establishing a General Bar Date to File Proofs of Claim, (II) Establishing a Bar Date for Governmental Units to File Proofs of Claim, (III) Establishing a Bar Date to File Requests for Payment of Postpetition Administrative Claims, (IV) Establishing an Amended Schedules Bar Date, (V) Establishing a Rejection Damages Bar Date, (VI) Approving the Form and Manner for Filing Proofs of Claim, (VII) Approving the Proposed Notice of Bar Dates, and (VIII)As of the date of the filing of this Objection, the Debtor’s Claims Register reflects that approximately 210 proofs of claim (collectively, the “Proofs of Claim”) have been filed in the Chapter 11 Case asserting claims against the Debtor (each a “Claim,” and collectively, the “Claims”).For the reasons set forth below, the Debtor objects to each of the Claims identified on Exhibit A (the “Disallowed Claims”) and Exhibit B (the “Overstated Claim”) of the Proposed Order.For the reasons set forth herein and in Exhibit B to the Proposed Order, the Debtor objects to the Overstated Claim identified in Exhibit B and requests that such Claim be reduced and allowed in the amount identified under the column labeled “Modified Claim Amount” for the reasons set forth in Exhibit B. 20.To the extent that a response is filed regarding any Claim identified in Exhibits A-B of the Proposed Order and the Debtor is unable to resolve the response, such Claim, and the objection to such Claim asserted by the Debtor herein, shall constitute a separate contested matter as contemplated by Bankruptcy Rule 9014.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 KLAUSNER LUMBER ONE LLC, Case No. 20-11033 (KBO) Debtor.1 Objection Deadline: May 13, 2021, at 4:00 p.m. (ET) Hearing Date: May 20, 2021, at 10:00 a.m. (ET) DEBTOR’S SIXTH OMNIBUS OBJECTION (SUBSTANTIVE) TO CERTAIN CLAIMS PURSUANT TO 11 U.S.C. § 502, FED. R. BANKR. P. 3007 AND DEL. L.R. 3007-1 (DISALLOW; REDUCE AND ALLOW) TO THE CLAIMANTS LISTED IN EXHIBITS A-B ATTACHED TO THE PROPOSED ORDER (AS DEFINED HEREIN): • YOUR RIGHTS MAY BE AFFECTED BY THIS OBJECTION AND BY ANY FURTHER OBJECTION(S) THAT MAY BE FILED BY THE DEBTOR OR ANY OTHER PARTY. • THE RELIEF SOUGHT HEREIN IS WITHOUT PREJUDICE TO THE RIGHTS OF THE DEBTOR OR ANY OTHER PARTY TO PURSUE FURTHER SUBSTANTIVE OR NON-SUBSTANTIVE OBJECTIONS AGAINST THE CLAIMS LISTED IN EXHIBITS A-B • CLAIMANTS RECEIVING THIS OBJECTION SHOULD LOCATE THEIR NAMES AND CLAIMS IN EXHIBITS A-B. The above-captioned debtor and debtor-in-possession (the “Debtor”) in this chapter 11 case (the “Chapter 11 Case”), by and through its undersigned counsel, hereby objects (the “Objection”) pursuant to section 502 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 3007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) and Local Rule 3007-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”) to those certain claims listed on Exhibits A-B which 1 The last four digits of the Debtor’s federal EIN is 9109. The Debtor’s mailing address is Klausner Lumber One LLC, P.O. Box 878, Middleburg, VA 20118.

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are attached to the proposed form of order (the “Proposed Order”) attached hereto as Exhibit 2, and incorporated herein by reference. In support of this Objection, the Debtor submits the Declaration of Michael Freeman in Support of the Debtor’s Sixth Omnibus Objection (Substantive) to Certain Claims Pursuant to 11 U.S.C. § 502, Fed. R. Bankr. P. 3007 and Del. L.R. 3007-1 (Disallow; Reduce and Allow) (the “Freeman Declaration”), attached hereto as Exhibit 1 and incorporated herein by reference, and respectfully states as follows: JURISDICTION AND VENUE 1. The United States Bankruptcy Court for the District of Delaware (the “Court”) has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 2. The statutory predicates for the relief requested herein are section 502 of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1. BACKGROUND A. The Chapter 11 Case 3. On April 30, 2020 (the “Petition Date”), the Debtor filed a voluntary petition under chapter 11 of the Bankruptcy Code. The Debtor continues to operate its business and manage its property as debtor-in-possession pursuant to §§ 1107(a) and 1108 of the Bankruptcy Code. 4. On May 21, 2020, the Office of the United States Trustee for the District of Delaware (the “U.S. Trustee”) appointed the official committee of unsecured creditors in this case (the “Creditors’ Committee”). B. The Claims Resolution Process in the Chapter 11 Case 5. On May 14, 2020, the Court entered an order [D.I. 59] appointing Donlin Recano & Company (“DRC”) as claims and noticing agent in this Chapter 11 Case. DRC is designated as

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the authorized repository for proofs of claim in the Chapter 11 Case and is authorized to maintain the official claims register (the “Claims Register”) for the Debtor to provide public access to every proof of claim unless otherwise ordered by the Court and to provide the Clerk with a certified duplicate thereof upon request of the Court. 6. On June 25, 2020, the Debtor filed its Schedules of Assets and Liabilities [D.I. 167] (the “Schedules”)2 and its Statements of Income and Financial Affairs [D.I. 168] (the “SOFA”). 7. On August 26, 2020, the Court entered the Order (I) Establishing a General Bar Date to File Proofs of Claim, (II) Establishing a Bar Date for Governmental Units to File Proofs of Claim, (III) Establishing a Bar Date to File Requests for Payment of Postpetition Administrative Claims, (IV) Establishing an Amended Schedules Bar Date, (V) Establishing a Rejection Damages Bar Date, (VI) Approving the Form and Manner for Filing Proofs of Claim, (VII) Approving the Proposed Notice of Bar Dates, and (VIII) Granting Related Relief [D.I 324] (the “Bar Date Order”), which established, among other things, the bar dates for general and administrative claims as October 30, 2020 at 5:00 p.m. (ET) (the “Bar Date”). 8. On September 2, 2020, DRC duly served the notice of the bar dates [D.I. 355 (the “Bar Date Notice”). 9. As of the date of the filing of this Objection, the Debtor’s Claims Register reflects that approximately 210 proofs of claim (collectively, the “Proofs of Claim”) have been filed in the Chapter 11 Case asserting claims against the Debtor (each a “Claim,” and collectively, the “Claims”). 2 On January 29, 2021, the Debtor filed amended Schedules of Assets and Liabilities [D.I. 686] (the “Amended Schedules”). The Amended Schedules did not affect the claims that are the subject of this Objection.

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10. The Debtor and its advisors are comprehensively reviewing and reconciling all claims, including both the claims listed on the Schedules (the “Scheduled Claims”) and the Claims asserted in the proofs of Claim (including any supporting documentation) filed in the Chapter 11 Case. 11. The Debtor is also comparing the Claims asserted in the Proofs of Claim with the Debtor’s books and records, maintained in the ordinary course of business (the “Books and Records”), to determine the validity of the asserted Claims. 12. This reconciliation process includes identifying particular categories of Claims that the Debtor believes should be disallowed or modified. To avoid a possible double recovery or otherwise improper recovery by claimants, the Debtor will continue to file omnibus objections to such categories of Claims if and where warranted. This Objection is one such omnibus objection. RELIEF REQUESTED 13. For the reasons set forth below, the Debtor objects to each of the Claims identified on Exhibit A (the “Disallowed Claims”) and Exhibit B (the “Overstated Claim”) of the Proposed Order. By this Objection, the Debtor respectfully requests that the Court enter an order pursuant to section 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1 disallowing or modifying the Claims as requested herein. BASIS FOR RELIEF 14. Pursuant to section 101 of the Bankruptcy Code, a creditor holds a claim against a bankruptcy estate only to the extent that (a) it has a “right to payment” for the asserted liabilities and (b) the claim is otherwise allowable. 11 U.S.C. §§ 101(5), (10). 15. When asserting a claim against a bankrupt estate, a claimant must allege facts that, if true, would support a finding that the debtor is legally liable to the claimant. See In re Allegheny Int’l Inc., 954 F.2d 167, 173 (3d Cir. 1992); Svenska Taendsticks Fabrik Aktiebolaget v. Irving Tr.

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Co. (In re Int’l Match Corp.), 69 F.2d 73, 76 (2d Cir. 1934) (finding that a proof of claim should at least allege facts from which legal liability can be seen to exist). Where the claimant alleges sufficient facts to support its claim, its claim is afforded prima facie validity. Allegheny Int’l, 954 F.2d at 173. A party wishing to dispute such a claim must produce evidence in sufficient force to negate the claim’s prima facie validity. Id. In practice, the objecting party must produce evidence that would refute at least one of the allegations essential to the claim’s legal sufficiency. Id. at 173-74. Once the objecting party produces such evidence, the burden shifts back to the claimant to prove the validity of its claim by a preponderance of the evidence. Id. at 174. The burden of persuasion is always on the claimant. Id. A. Disallowed Claims (Exhibit A) 16. For the reasons set forth herein and in Exhibit A to the Proposed Order, the Debtor objects to the Disallowed Claims because the Disallowed Claims assert claims for which the Debtor’s Books and Records reflect that there is no amount due and owing by the Debtor to the particular claimant. 17. The Disallowed Claims should be disallowed in full because, based on careful review of the Books and Records, the Schedules and any amendments thereto, and the Proofs of Claim, including supporting documentation provided by the claimant, if any, the Debtor believes that there is no amount due and owing to the claimant with respect to such claim. 18. Accordingly, the Disallowed Claims should be disallowed as a matter of law. B. Overstated Claim (Exhibit B) 19. For the reasons set forth herein and in Exhibit B to the Proposed Order, the Debtor objects to the Overstated Claim identified in Exhibit B and requests that such Claim be reduced and allowed in the amount identified under the column labeled “Modified Claim Amount” for the reasons set forth in Exhibit B.

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20. Based on the Debtor’s careful review of the Books and Records, the Schedules and any amendments thereto, and the Proofs of Claim, including supporting documentation provided by the claimant, if any, the Debtor has determined that: (i) the Claim, itself, is overstated as to the Debtor, and (ii) a portion of the Overstated Claim is not due and owing from the Debtor but, rather, has already been partially paid to the claimant by another Klausner entity, Klausner Holz Thüringen GMBH (“KTH”). 21. Unless the Overstated Claim is reduced as requested herein, the claimant will receive a surplus in excess of its actual claim from the Debtor in contravention of the provisions and policies of the Bankruptcy Code and to the direct detriment of the Debtor, its estate and its creditors. 22. Accordingly, the Overstated Claim should be reduced and allowed in the amount set forth in Exhibit B of the Proposed Order. SEPARATE CONTESTED MATTERS 23. To the extent that a response is filed regarding any Claim identified in Exhibits A-B of the Proposed Order and the Debtor is unable to resolve the response, such Claim, and the objection to such Claim asserted by the Debtor herein, shall constitute a separate contested matter as contemplated by Bankruptcy Rule 9014. Any order entered by the Court regarding an objection asserted in this Objection shall be deemed a separate order with respect to each Claim. RESPONSES TO OMNIBUS OBJECTION 24. To contest an objection, a claimant must file and serve a written response to this Objection (a “Response”) so that it is received no later than May 13, 2021 at 4:00 p.m. (ET) (the “Response Deadline”). Every Response must be filed with the Office of the Clerk of the United States Bankruptcy Court for the District of Delaware: 824 N. Market Street, Wilmington, Delaware

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19801, and served upon the following entity so that the Response is received no later than the Response Deadline, at the following address: DUANE MORRIS LLP Attn: Lawrence J. Kotler, Esq. 222 Delaware Avenue, Suite 1600 Wilmington, DE 19801-1659 Bankruptcy Conflicts Counsel and Labor/ERISA Counsel for Debtor and Debtor in Possession 25. Every Response to this Objection must contain, at a minimum, the following information: I. A caption setting forth the name of the Court, the name of the Debtor, the case number, and the title of the Objection to which the Response is directed; II. The name of the claimant, the claim number, and a description of the basis for the amount of the Claim; III. The specific factual basis and supporting legal argument upon which the party will rely in opposing this Objection; IV. Any supporting documentation, to the extent that it was not included in the Proof of Claim previously filed with the clerk or DRC, upon which the claimant intends to rely to support the basis for and amounts asserted in the Proof of Claim; and V. The name, address, telephone number and fax number of the person(s) (which may be the claimant or the claimant’s legal representative) with whom counsel for the Debtor should communicate with respect to the Claim or the Objection and who possesses authority to reconcile, settle, or otherwise resolve the Objection to the disputed Claim on behalf of the claimant. 26. If a claimant fails to file and serve a timely Response by the Response Deadline, the Debtor may present to the Court an appropriate order reclassifying, modifying, or disallowing the Claim without further notice to the claimant or a hearing.

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ADJOURNMENT OF HEARING 27. The Debtor reserves the right to seek an adjournment of the hearing on any Responses to this Objection. In the event that the Debtor seeks such an adjournment, it will be noted on the notice of agenda for the hearing, and such agenda will be served on the affected claimant by serving the person designated in the Response. RESERVATION OF RIGHTS 28. Nothing contained in this Objection nor any actions taken by the Debtor or any other party pursuant to relief that may be granted by entry of the Proposed Order is intended or should be construed as: (i) an admission as to the validity of any particular Claim (including any Proof of Claim) against the Debtor or any other party; (ii) a waiver of the Debtor’s or any other party’s rights to dispute any particular Claim (including any Proof of Claim); (iii) a promise or requirement to pay any particular Claim (including any Proof of Claim); (iv) an implication or admission that any particular Claim (including any Proof of Claim) is of a priority or type specified in this Objection; or (v) a waiver or limitation of the Debtor’s or any other party’s rights under the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, or any other applicable law. 29. The Debtor expressly reserves the right to amend, modify, or supplement this Objection. Should one or more of the grounds of objection stated in this Objection be dismissed or overruled, the Debtor reserves the right to object to each of the Proofs of Claim on any other grounds that the Debtor discovers or elects to pursue. This Objection sets out certain substantive objections to the Proofs of Claim identified on Exhibits A-B to the Proposed Order. The Debtor and any other party, as applicable, reserve the right to assert other substantive objections and/or non-substantive objections to the proofs of Claim identified on Exhibits A-B to the Proposed Order.

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NO PRIOR REQUEST 30. No prior request for the relief sought herein has been made to this or any other court. NOTICE 31. Notice of this Objection will be given to: (a) the Office of the United States Trustee for the District of Delaware; (b) each of the parties listed on Exhibits A-B of the Proposed Order; and (c) all parties requesting notice pursuant to Bankruptcy Rule 2002. The Debtor submits that, under the circumstances, no other or further notice is required. WHEREFORE, the Debtor respectfully requests that the Court (i) enter an order substantially in the form attached hereto as Exhibit 2, modifying or disallowing the Claims as requested herein, and (ii) grant such other and further relief as is just and proper. Dated: April 20, 2021 DUANE MORRIS LLP Wilmington, Delaware /s/ Lawrence J. Kotler______________ Lawrence J. Kotler (DE Bar No. 4181) 222 Delaware Avenue, Suite 1600 Wilmington, DE 19801-1659 Telephone: (302) 657-4900 Facsimile: (302) 657-4901 Email: LJKotler@duanemorris.com Bankruptcy Conflicts Counsel and Labor/ERISA Counsel for Debtor and Debtor in Possession

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