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Full title: Certificate of No Objection Pursuant to LR 9075-2 Regarding Motion Of Litigation Trustee To Extend Deadlines For Filing Objections To (I) 503(B)(9) And Other Administrative Claims, And (II) General Unsecured Claims (related document(s)1986) Filed by Jay Indyke on behalf of Litigation Trustee of the Miami Metals Litigation Trust. (Indyke, Jay) (Entered: 08/09/2021)

Document posted on Aug 8, 2021 in the bankruptcy, 2 pages and 0 tables.

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: -------------------------------------- X CERTIFICATE OF NO OBJECTION REGARDING MOTION OF LITIGATION TRUSTEE TO EXTEND DEADLINES FOR FILING OBJECTIONS TO (I) 503(B)(9) AND OTHER ADMINISTRATIVE CLAIMS, AND (II)UNSECURED CLAIMS PLEASE TAKE NOTICE that on July 13, 2021, Donna H. Lieberman, in her capacity as the litigation trustee of the Miami Metals Litigation Trust (the “Litigation Trustee”), filed the Motion of the Litigation Trustee to Extend Deadlines for Filing Objections to (I) 503(B)(9) and Other Administrative Claims, and (II)The sole remaining Debtor in this chapter 11 case is Miami Metals I, Inc. (f/k/a Republic Metals Refining Corporation), 15 West 47th Street, Suites 206 and 209, New York, NY 10036 (last four digits of federal tax identification number: 3194). PLEASE TAKE FURTHER NOTICE that the Litigation Trustee established a deadline for parties to file objections to the Motion (the “Objection Deadline”). PLEASE TAKE FURTHER NOTICE that the Litigation Trustee respectfully requests that the proposed order attached to the Motion be entered prior to the hearing currently scheduled for August 12, 2021 at 2:00 p.m. (prevailing Eastern Time).

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COOLEY LLP 55 Hudson Yards New York, New York 10001 Telephone: 212-479-6000 Facsimile: (212) 479-6275 Jay Indyke Paul Springer Counsel for the Litigation Trustee UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------- X : Chapter 11 In re: : Case No. 18-13359 (SHL) MIAMI METALS I, INC., et al.,1 : Debtors. : -------------------------------------- X CERTIFICATE OF NO OBJECTION REGARDING MOTION OF LITIGATION TRUSTEE TO EXTEND DEADLINES FOR FILING OBJECTIONS TO (I) 503(B)(9) AND OTHER ADMINISTRATIVE CLAIMS, AND (II) GENERAL UNSECURED CLAIMS PLEASE TAKE NOTICE that on July 13, 2021, Donna H. Lieberman, in her capacity as the litigation trustee of the Miami Metals Litigation Trust (the “Litigation Trustee”), filed the Motion of the Litigation Trustee to Extend Deadlines for Filing Objections to (I) 503(B)(9) and Other Administrative Claims, and (II) General Unsecured Claims [ECF No. 1986] (the “Motion”) 1 The sole remaining Debtor in this chapter 11 case is Miami Metals I, Inc. (f/k/a Republic Metals Refining Corporation), 15 West 47th Street, Suites 206 and 209, New York, NY 10036 (last four digits of federal tax identification number: 3194). The cases for the prior Debtors were closed on April 3, 2020 pursuant to the Final Decree (I) Closing Subsidiary Cases and (II) Granting Related Relief (the “Subsidiary Final Decree”) [ECF No. 1746]. Pursuant to the terms of the Subsidiary Final Decree, the Litigation Trustee is authorized to object to claims asserted against any or all of the Debtors in the remaining case.

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with the United States Bankruptcy Court for the Southern District of New York (the “Bankruptcy Court”). PLEASE TAKE FURTHER NOTICE that the Litigation Trustee established a deadline for parties to file objections to the Motion (the “Objection Deadline”). The Objection Deadline was set for August 5, 2021, at 5:00 p.m. (prevailing Eastern Time). The Objection Deadline has now passed and, to the best of my knowledge, no responsive pleadings have been filed or otherwise received. PLEASE TAKE FURTHER NOTICE that the Litigation Trustee respectfully requests that the proposed order attached to the Motion be entered prior to the hearing currently scheduled for August 12, 2021 at 2:00 p.m. (prevailing Eastern Time). However, a hearing to consider the Motion may still be held at such time should the Bankruptcy Court require. Dated: August 9, 2021 New York, New York /s/ Jay Indyke Jay Indyke Paul Springer COOLEY LLP 55 Hudson Yards New York, New York 10001 Telephone: (212) 479-6000 Facsimile: (212) 479-6275 Email: jindyke@cooley.com pspringer@cooley.com Counsel for the Litigation Trustee

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