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Full title: Response with Certificate of Service and Reservation of Rights of the Official Committee of Unsecured Creditors to Debtor's Motion for Entry of Orders: (I) Approving Bidding Procedures and Stalking Horse Protections, and (II) Authorizing the Sale of Immovable Property Filed by Official Committee of Unsecured Creditors (RE: (related document(s)889 Motion For Sale of Property Free and Clear of Liens under 11 USC 363(f) filed by Debtor The Roman Catholic Church for the Archdiocese of New Orleans) Hearing scheduled for 6/17/2021 at 01:30 PM by SECTION A TeleConference Line: 1-888-684-8852 Access Code 9318283. (Attachments: # 1 Exhibit A # 2 Exhibit B) (Boldissar, C.) (Entered: 06/14/2021)

Document posted on Jun 13, 2021 in the bankruptcy, 4 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

§ § LIMITED RESPONSE AND RESERVATION OF RIGHTS OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS TO DEBTOR’S MOTION FOR ENTRY OF ORDERS: (I) APPROVING BIDDING PROCEDURES AND STALKING HORSE PROTECTIONS, AND (II) AUTHORIZING THE SALE OF IMMOVABLE PROPERTY [Relates to Docket #889] [Docket No. 889] (the “Sale Motion”) seeking approval of the sale of the property located at 4119 St. Elizabeth Drive, Kenner, Louisiana 70065 (the “St. Elizabeth Property”), stating as follows.The Sale Motion is a fairly standard Section 363 motion to approve an auction and sale process for the St. Elizabeth Property, and under the motion, the Debtor requests entry of two orders, including first, an order (the “Bidding Procedures Order”) approving bidding procedures (the “Bidding Procedures”), and second, after an auction is conducted and a further 1 sale hearing, entry of an order approving the sale (the “Sale Order”).The Committee does not object to the entry of the Bidding Procedures Order, provided that certain minor revisions are made (which include revisions made by the Official Committee of Unsecured Commercial Creditors, or the “Commercial Committee”), which are being discussed with the Debtor and the Commercial Committee.I hereby caused a copy of the foregoing Limited Response to be served on June 14, 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 June 15, 2021.

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA IN RE: § Case No. 20-10846 § THE ROMAN CATHOLIC CHURCH § Section “A” OF THE ARCHDIOCESE OF NEW § ORLEANS § Chapter 11 § Debtor. § § LIMITED RESPONSE AND RESERVATION OF RIGHTS OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS TO DEBTOR’S MOTION FOR ENTRY OF ORDERS: (I) APPROVING BIDDING PROCEDURES AND STALKING HORSE PROTECTIONS, AND (II) AUTHORIZING THE SALE OF IMMOVABLE PROPERTY [Relates to Docket #889] The Official Committee of Unsecured Creditors (the “Committee”) hereby submits this Limited Response and Reservation of Rights (the “Limited Response”) in connection with the Debtor’s Motion for Entry of Orders: (I) Approving Bidding Procedures and Stalking Horse Protections, and (II) Authorizing the Sale of Immovable Property [Docket No. 889] (the “Sale Motion”) seeking approval of the sale of the property located at 4119 St. Elizabeth Drive, Kenner, Louisiana 70065 (the “St. Elizabeth Property”), stating as follows. 1. The Sale Motion concerns a nine-acre vacant school campus in Kenner, Louisiana in a residential area. The Committee generally does not oppose the sale of this property provided that the property is adequately and appropriately marketed to achieve the best value for the estate, with proceeds being escrowed pending further proceedings. 2. The Sale Motion is a fairly standard Section 363 motion to approve an auction and sale process for the St. Elizabeth Property, and under the motion, the Debtor requests entry of two orders, including first, an order (the “Bidding Procedures Order”) approving bidding procedures (the “Bidding Procedures”), and second, after an auction is conducted and a further 1

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sale hearing, entry of an order approving the sale (the “Sale Order”). 3. The Committee does not object to the entry of the Bidding Procedures Order, provided that certain minor revisions are made (which include revisions made by the Official Committee of Unsecured Commercial Creditors, or the “Commercial Committee”), which are being discussed with the Debtor and the Commercial Committee. The Committee expects that the parties will be in agreement on these language edits, but in an abundance of caution, the requested language edits are set forth in the redlines attached as Exhibit “A” hereto (Bidding Procedures Order) and Exhibit “B” hereto (Bidding Procedures).14. As for the entry of the Sale Order, the Committee reserves rights as to entry of that order and as to ultimate approval of the sale. In order for the Sale Order to be entered, among other things, the Debtor must establish that the St. Elizabeth Property has been appropriately marketed and advertised, and that potential bidders have been contacted and have had a reasonable and appropriate opportunity to review and bid on the property. E.g., In re Gulf Coast Oil Corp., 404 B.R. 407, 423 (Bankr. S.D.Tex. 2009) (“The principal justification for § 363(b) sales is that aggressive marketing in an active market assures that the estate will receive maximum benefit.”); In re Eagle Broadband, Inc., 2009 WL 1067128, *1, Case No. 07-80605 (Bankr. S.D.Tex. April 9, 2009) (denying approval of Section 363 sale where trustee’s testimony failed to establish appropriate “marketing efforts [which] would result in the highest price for the estate assets”). 5. In addition, the Committee reserves rights as to the impact of deed restrictions included in the draft act of sale. [Docket 889-5 at p. 18 of the PDF] In the event that such deed restrictions impact value or any bids, there may be an impact on the Section 363 analysis, to be 1 These redlines reflect changes from the versions filed by the Debtor on the docket with the original motion as of May 27, 2021 [Docket #889]. 2

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raised either in advance of, or at the sale hearing. 6. The Committee is awaiting the receipt of information from the Debtor as to the marketing of the St. Elizabeth Property. The property should be appropriately marketed and advertised in order for this Court to approve the sale under Section 363. 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: June 14, 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- 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 3

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CERTIFICATE OF SERVICE I hereby caused a copy of the foregoing Limited Response to be served on June 14, 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 June 15, 2021. /s/ C. Davin Boldissar C. Davin Boldissar 4

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