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Full title: Objection with Certificate of Service to the Joint Motion of the Debtor and the Official Committee of Unsecured Creditors to Appoint Mediator Filed by First State Insurance Company, Twin City Insurance Company (RE: (related document(s)982 Generic Motion filed by Debtor The Roman Catholic Church for the Archdiocese of New Orleans) Hearing scheduled for 8/19/2021 at 01:30 PM by SECTION A TeleConference Line: 1-888-684-8852 Access Code 9318283. (Attachments: # 1 Exhibit Proposed Order) (Maloz, Wilson) (Entered: 08/12/2021)

Document posted on Aug 11, 2021 in the bankruptcy, 4 pages and 0 tables.

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THE ARCHDIOCESE OF NEW ORLEANS, Section “A” Debtor.1 Chapter 11 LIMITED OBJECTION OF PARTIES IN INTEREST TWIN CITY FIRE INSURANCE COMPANY AND FIRST STATE INSURANCE COMPANYTO THE JOINT MOTION OF THE DEBTOR AND THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS TO APPOINT MEDIATOR Twin City Fire Insurance Company and First State Insurance Company, parties in interest in this chapter 11 case, by and through undersigned counsel, respectfully submit this limited objection to the Joint Motion of the Debtor and the Official Committee of Unsecured Creditors to Appoint Mediator filed on July 29, 2021 (Doc. 982) (the “Motion”).The Debtor has tendered to Hartford numerous proofs of claim filed in the above-captioned chapter 11 case asserting sexual misconduct by a priest or other individual for which the Debtor is allegedly responsible (the “POCs”) during periods allegedly covered by the Hartford Policies.Consequently, Hartford respectfully requests that the Court modify the proposed Order, and enter an Order substantially in the form attached hereto as Exhibit A, to provide that Debtor and the Committee will meet and confer with Hartford—and any other interested party that wants to be heard—on an appropriate mediator for resolution of coverage issues.That may be the same mediator that parties select to hear other issues in the case, or a separate mediator that has special expertise in resolving coverage issues.

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA In re: THE ROMAN CATHOLIC CHURCH OF Case No. 20-10846 THE ARCHDIOCESE OF NEW ORLEANS, Section “A” Debtor.1 Chapter 11 LIMITED OBJECTION OF PARTIES IN INTEREST TWIN CITY FIRE INSURANCE COMPANY AND FIRST STATE INSURANCE COMPANY TO THE JOINT MOTION OF THE DEBTOR AND THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS TO APPOINT MEDIATOR Twin City Fire Insurance Company and First State Insurance Company, parties in interest in this chapter 11 case, by and through undersigned counsel, respectfully submit this limited objection to the Joint Motion of the Debtor and the Official Committee of Unsecured Creditors to Appoint Mediator filed on July 29, 2021 (Doc. 982) (the “Motion”). OBJECTION 1. Twin City Fire Insurance Company and First State Insurance Company (collectively, “Hartford”) issued excess/umbrella liability coverage to Debtor, the Roman Catholic Church of the Archdiocese of New Orleans (“Debtor”) for periods of time between 1981 and 1983 (the “Hartford Policies”). The Debtor has tendered to Hartford numerous proofs of claim filed in the above-captioned chapter 11 case asserting sexual misconduct by a priest or other individual for which the Debtor is allegedly responsible (the “POCs”) during periods allegedly covered by the Hartford Policies. Hartford accordingly has a stake in how mediation proceeds in this case. 1 The last four digits of the Debtor’s federal tax identification number are 8966. The Debtor’s principal place of business is located at 7887 Walmsley Ave., New Orleans, LA 70125.

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2. Paragraph 3 of the proposed order submitted with the Motion (Doc. 982-1) indicates that the parties to the mediation include “the Debtor’s insurance carriers,” which carriers include Hartford, and paragraph 7 of the Motion indicates that “[t]he parties have discussed and agreed that the Hon. Gregg W. Zive should be appointed as the mediator.” 3. Hartford agrees with the Debtor and Official Committee of Unsecured Creditors (“Committee”) that mediation is an appropriate course of action. A consensual chapter 11 plan is the best way to bring the most complete relief to all interested parties. 4. Hartford is concerned, however, because Hartford was not included the “discuss[ions]” referenced in the Motion. Indeed, the Debtor and the Official Committee of Unsecured Creditors (“Committee”) have made one of the most fundamental and important decisions concerning the mediation – selection of a mediator – without any opportunity for input from Hartford (and potentially the Debtor’s other liability insurers). 5. Hartford does not dispute that Judge Zive has extensive experience in mediating this type of bankruptcy case. But Judge Zive is not the only such candidate, and there may be other candidates that also have expertise in understanding the nature of the underlying tort claims and/or who have particular experience in evaluation of claims venued in Louisiana, which is the most relevant jurisdiction in this case. 6. Hartford is aware that the Debtor’s insurance coverage program contains numerous insurers, and that it may not be possible to reach agreement with all interested parties on a mediator. But there should be no doubt that mediation has the greatest prospect for success if all parties – particularly those that may be asked to contribute substantial funding towards a settlement – are invested in the most fundamental decisions regarding that mediation, including a full and fair opportunity to weigh in on an appropriate mediator.

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7. Consequently, Hartford respectfully requests that the Court modify the proposed Order, and enter an Order substantially in the form attached hereto as Exhibit A, to provide that Debtor and the Committee will meet and confer with Hartford—and any other interested party that wants to be heard—on an appropriate mediator for resolution of coverage issues. That may be the same mediator that parties select to hear other issues in the case, or a separate mediator that has special expertise in resolving coverage issues. If the relevant stakeholders cannot agree following good faith discussion, then Debtors can seek assistance of the Court. But that should not precede efforts by the parties to find a mediator that is satisfactory to all those who are likely to be directly involved. Accordingly, Hartford respectfully requests that the Court sustain Hartford’s limited objection and enter Hartford’s proposed revised Order. Dated: August 12, 2021 Respectfully submitted, /s/ Wilson L. Maloz, III Wilson L. Maloz, III (# 26396) Larzelere Picou Wells Simpson Lonero, LLC Two Lakeway Center - Suite 500 3850 N. Causeway Boulevard Metairie, LA 70002 Telephone: 504-834-6500 Facsimile: 504-834-6565 wmaloz@lpwsl.com -and- James P. Ruggeri (pro hac vice forthcoming) Joshua D. Weinberg (pro hac vice forthcoming) Shipman & Goodwin LLP 1875 K Street, NW, Suite 600 Washington, D.C. 20006 Tel: (202) 469-7750 Fax: (202) 469-7751 jruggeri@goodwin.com jweinberg@goodwin.com

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Attorneys for Twin City Fire Insurance Company and First State Insurance Company CERTIFICATE OF SERVICE I hereby certify that on this 12th day of August, 2021, I electronically filed the foregoing with the Clerk of Court by using the CM/ECF system, which will send a notice of electronic filing to all counsel registered for electronic service. /s/ Wilson L. Maloz, III

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