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Full title: Response with Certificate of Service Limited Response Filed by Official Committee of Unsecured Creditors (RE: (related document(s)854 Application to Employ with Affidavit of Disinterestedness filed by Creditor Committee Official Committee of Unsecured Commercial Creditors) Hearing scheduled for 5/20/2021 at 01:30 PM by SECTION A TeleConference Line: 1-888-684-8852 Access Code 9318283. (Boldissar, C.) (Entered: 05/17/2021)

Document posted on May 16, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

This amount does not include: (i) the bondholder claim which is subject to the treatment under the Court’s Order at Docket #527; (ii) PPP loans which the Committee understands will be forgiven; (iii) unfunded pension liability; (iv) event refund claims which are generally being paid under the 3.Second, the Committee briefly highlights the disclosure made in the Application for the first time.On March 16, 2021, the Commercial Committee received a communication from counsel to TMI Trust Company ("TMI") requesting the opportunity to join the Commercial Committee in an ex officio capacity. WHEREFORE, the Committee respectfully requests that the concerns above be addressed, and that the Committee be granted all other proper relief under law or at equity.I hereby caused a copy of the foregoing Limited Response to be served on May 17, 2021 upon all parties by electronic case filing for those parties receiving notice via the Court’s Electronic Case Filing system, and on all other parties requiring service under the Court’s Ex Parte Order Authorizing the Debtor to Limit Notice and Establishing Notice Procedures through the Special Notice List via first-class U.S. mail, postage prepaid, to be sent on May 18, 2021.

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA In re: ) ) Case No. 20-10846 THE ROMAN CATHOLIC CHURCH OF ) THE ARCHDIOCESE OF NEW ORLEANS ) Section “A” ) Debtor. ) Chapter 11 LIMITED RESPONSE OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS CONCERNING APPLICATION FOR ENTRY OF AN ORDER AUTHORIZING THE RETENTION AND EMPLOYMENT OF DUNDON ADVISERS LLC, AS FINANCIAL ADVISOR TO THE OFFICIAL COMMITTEE OF UNSECURED COMMERCIAL CREDITORS EFFECTIVE AS OF APRIL 14, 2021 [Relates to Docket #854] The Official Committee of Unsecured Creditors (the “Committee”) hereby submits this limited response (this “Limited Response”) in connection with the Application for Entry of an Order Authorizing the Retention and Employment of Dundon Advisors LLC, as Financial Advisor to the Official Committee of Unsecured Commercial Creditors Effective as of April 14, 2021 [Docket #854] (the “Application”) filed by The Official Committee of Unsecured Commercial Creditors (the “Commercial Committee”). 1. The Committee does not object to the retention of the proposed financial advisor, but files this Limited Response only to address two limited points. 2. First, the scope of work for the Commercial Committee’s financial advisor should be limited and commensurate with its constituency’s financial issues in this case. The Committee understands that the total amount of scheduled “trade” claims in this case total less than $5 million, of which approximately $1.5 million are employee and employee health claims.1 1 This is based on preliminary review of filed claims and the Debtor’s schedules. This amount does not include: (i) the bondholder claim which is subject to the treatment under the Court’s Order at Docket #527; (ii) PPP loans which the Committee understands will be forgiven; (iii) unfunded pension liability; (iv) event refund claims which are generally being paid under the

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3. In particular, in the event that the parties reach an agreement as to full payment of the Commercial Committee’s class of creditors (subject to claim objections), there should be no significant expense after that point. 4. Second, the Committee briefly highlights the disclosure made in the Application for the first time. Footnote 2, at Paragraph 5 of the Application states: On March 16, 2021, the Commercial Committee received a communication from counsel to TMI Trust Company ("TMI") requesting the opportunity to join the Commercial Committee in an ex officio capacity. After careful consideration, on April 7, 2021, the Commercial Committee determined to grant TMI's request to become an ex officio member of the Commercial Committee. For the avoidance of doubt, TMI is a non-voting member of the Commercial Committee and does not owe any fiduciary duties to unsecured creditors as a result of its ex officio seat on the Commercial Committee. 5. This disclosure was not made until the Application was filed. The Committee is reviewing all implications and all rights are reserved. WHEREFORE, the Committee respectfully requests that the concerns above be addressed, and that the Committee be granted all other proper relief under law or at equity. Dated: May 17, 2021 Respectfully submitted, /s/ C. Davin Boldissar Omer F. Kuebel, III (La #21682) C. Davin Boldissar (La. #29094) Locke Lord LLP 601 Poydras Street, Suite 2660 New Orleans, Louisiana 70130-6036 Telephone: (504) 558-5111 Facsimile: (504) 558-5200 Email: dboldissar@lockelord.com -and- (continued…) Order at Docket #162; and (v) the claim [Claim #197] asserted by the United States for civil damages, for which there is a preliminary settlement as set forth in the claim.

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James I. Stang (CA Bar No. 94435) Linda F. Cantor (CA Bar No.153762) Pachulski Stang Ziehl & Jones LLP 10100 Santa Monica Blvd., Suite 1300 Los Angeles, CA 90067 Telephone: (310) 277-6910 Facsimile: (310) 201-0760 Co-Counsel to the Official Committee of Unsecured Creditors CERTIFICATE OF SERVICE I hereby caused a copy of the foregoing Limited Response to be served on May 17, 2021 upon all parties by electronic case filing for those parties receiving notice via the Court’s Electronic Case Filing system, and on all other parties requiring service under the Court’s Ex Parte Order Authorizing the Debtor to Limit Notice and Establishing Notice Procedures through the Special Notice List via first-class U.S. mail, postage prepaid, to be sent on May 18, 2021. /s/ C. Davin Boldissar C. Davin Boldissar

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