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Full title: Motion for relief from judgment or order filed by Interested Party DCC Propane, LLC re: 54 Order on miscellaneous motion (first day motion). An affidavit or verification, Memorandum of law, Proposed order. Hearing scheduled 6/8/2021 at 10:30 AM at Courtroom 2B, 2nd floor, 316 North Robert Street, St. Paul, Judge William J. Fisher. (Coleman, Samuel) (Entered: 05/17/2021)

Document posted on May 16, 2021 in the bankruptcy, 24 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

With respect to retrieving, filing, and routing legal notices, such as bankruptcy notices, an employee of DCC collects and then scans the documents into a computer and routes the documents electronically to the appropriate email address, person, or department.I am the attorney at Trott Law, P.C. and represent DCC Propane, LLC (“DCC”) inthis bankruptcy case. DCC operates under the name DCC Propane, LLC and under the assumed names of Hicksgas and Liberty Propane.For context in understanding how DCC reviews bankruptcy notices, DCC’s primary objective after receiving bankruptcy notices is to ensure that any dunning letters, invoices, statements, demands for payment or the like are not sent to a bankruptcy debtor.As instructed by my supervisor, my primary objective in dealing with bankruptcy notices was to take such actions to ensure that DCC was not sending demands for payment to customers who had filed for bankruptcy.

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Chapter 11 Tea Olive I, LLC d/b/a Stock + Field, Case No.: 21-30037 Debtor. NOTICE OF HEARING AND MOTION OF DCC PROPANE, LLC FOR RELIEF FROM ORDER UNDER FED. R. CIV. P. 60(b) AND FED. R. BANKR. P. 9006(b) 1. DCC Propane, LLC (“DCC”), and unsecured creditor of the debtor, by and through undersigned counsel, moves the Court for the relief requested herein and gives notice of hearing. 2. The Court will hold a hearing on this Motion at 10:30 a.m. (CT) on Tuesday, June 8, 2021, in Courtroom 2B, 232 Warren E. Burger Federal Building and U.S. Courthouse, 316 North Robert Street, St. Paul, MN 55101. Due to the COVID-19 pandemic, the hearing will be held telephonically. To participate: Dial 1-888-684-8852 When prompted, enter ACCESS CODE: 5988550 When prompted, enter SECURITY CODE: 0428 3. Any response to the Motion must be filed and served no later than Thursday, June 3, 2021,pursuant to the applicable Federal Rules of Bankruptcy Procedure (the “BankruptcyRules”) and the Local Rules. UNLESS A RESPONSE OPPOSING THE MOTION ISTIMELY FILED, THE COURT MAY GRANT THE MOTION WITHOUT AHEARING.

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4. This Court has jurisdiction over this Motion pursuant to 28 U.S.C. §§ 157 and 1334,Bankruptcy Rule 5005, and Local Rule 1070-1. This is a core proceeding. 5. This Motion arises under sections 105(a) and 1103 of Title 11 of the United States Code(the “Bankruptcy Code”). This Motion is filed under Bankruptcy Rule 9006(b), 9013 and9014 and Local Rules 9013-1 through 9013-3. 6. On January 14, 2021, the Court entered its Order (I) Granting Expedited Relief and (II)Establishing Procedures for the Resolution of Reclamation Claim and AdministrativeClaims Asserted Pursuant to Section 503(b)(9) of the Bankruptcy Code (Doc. 54)(the “20-day Order”). 7. The deadline for submitting claims under the 20-day Order was March 15, 2021. 8. DCC served its Reclamation and/or Twenty Day Claim pursuant to the 20-day Order onMarch 23, 2021. 9. The Debtor has objected to DCC’s Reclamation and/or Twenty Day Claim, in part, becauseit was submitted untimely. 10.DCC, pursuant to Fed. R. Bankr. P. 9006(b) and Fed. R. Civ. P. 60(b), seeks an ordergranting it relief from the 20-day Order upon demonstrated excusable neglect and goodcause. 11.A recitation of the facts and record in support of this Motion may be found in the attachedMemorandum of Law in Support of Motion for Relief from Order under Fed. R. Bankr. P. 9006(b) and Fed. R. Civ. P. 60(b). WHEREFORE, DCC respectfully requests that the Court enter an order granting it relief from the Court’s 20-day Order and deem DCC’s March 23, 2021 Reclamation and/or Twenty Day Claim as timely served and submitted.

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Respectfully submitted, TROTT LAW, P.C. Dated: May 17, 2021 By: /e/ Samuel R. Coleman Samuel R. Coleman (#389839) Attorneys for DCC Propane, LLC 25 Dale Street North St. Paul, MN 55102 Telephone: (651) 209-9785 scoleman@trottlaw.com

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Chapter 11 Tea Olive I, LLC d/b/a Stock + Field, Case No.: 21-30037 Debtor. MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR RELIEF FROM ORDER UNDER FED. R. CIV. P. 60(b) AND FED. R. BANKR. P. 9006(b) FACTUAL BACKGROUND DCC’s core business is selling propane and leasing propane dispensing equipment to retail outlets. (Kelsey Dec., p. 2, ¶¶ 6 and 8) Retailers, like the debtor here, resell the propane to its customers. (Id.) DCC has undergone dramatic changes since December of 2020 when it acquired United Propane Gas (“UPG”) on January 1, 2021. (Id., p. 3 ¶ 12) DCC’s acquisition of UPG more than doubled the number of DCC’s stores, employees, and customers. (Id.) The acquisition created numerous challenges. Jessica Kelsey—the primary employee overseeing the integration of UPG into DCC’s operations, policies and procedures—described the integration as challenging and hectic. (Kelsey Dec., p. 3, ¶ 14) It took her approximately three months, from January 1, 2021 through March of 2021, to achieve some stability in her daily work. (Id.) Barbara Kettner — the employee responsible for organizing bankruptcy related documents for DCC — was also affected by the acquisition-related challenges. (See generally, 1

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Kettner Dec.) Additionally, Ms. Kettner was dealing with significant health issues during the exact time this bankruptcy case was initiated. (Id.) This is DCC’s first encounter with a 20-day administrative expense claim. (Kelsey Dec., p. 4, ¶ 22; Kettner Dec., p. 3, ¶ 17) DCC’s prior experience with bankruptcies affected its customer was confined to ensuring that DCC did not violate the automatic stay. (Kelsey Dec., p. 5, ¶ 27; Kettner Dec., p. 3, ¶ 19) DCC has never been an active participant in a bankruptcy case, and did not have in-house legal counsel until December 2020. (Kelsey Dec., p. 6, ¶ 36) It was in midst of the upheaval of these corporate changes and employee struggles that DCC received on January 29, 2021 the Order (I) Granting Expedited Relief and (II) Establishing Procedures for the Resolution of Reclamation Claims and Administrative Claims Asserted Pursuant to Section 503(b)(9) of the Bankruptcy Code (Doc. 54) (collectively, the “Administrative Claim Notice”). (Id., p. 4, ¶ 21) Due to these difficulties, the Administrative Claim Note was left unaddressed until late March, after DCC had retained outside counsel to assist on March 20211. (Id. at ¶ 24) Per the Court’s Order, 20-day claims under 503(b)(9) were required to be received by debtor’s counsel on or before March 15, 2021. Undersigned counsel discovered the Administrative Claim Notice in PACER on March 17, 2021 during a thorough review of all of the filings in this case. (Coleman Dec., p. 2, ¶ 4) DCC, through counsel, submitted its 20-day 1 A retainer agreement was not signed by DCC until March 17, 2021, but counsel did conduct some initial inquiries into the status of the case on March 15th and 16th. 2

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claim form on March 23, 2021. (Id. at ¶ 5) DCC asserts an administrative claim for goods delivered to the debtor within 20 days of the filing of this case. (Id. at Ex. A) JURISDICTION The Court has jurisdiction pursuant to 28 U.S.C. §§1334(a) and (b) as it involves the allowance or disallowance of claims against the bankruptcy estate and, thus, is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(B). STANDARD OF REVIEW Fed. R. Civ. P. 60(b), made applicable through Fed. R. Bankr. P. 9024, states, in pertinent part: (b) Mistakes; Inadvertence; Excusable Neglect; Newly Discovered Evidence; Fraud, Etc. On motion and upon such terms as are just, the court may relieve a party or a party’s legal representative from a final judgment, order, or proceeding for the following reasons: (1) mistake, inadvertence, surprise, or excusable neglect; … The motion shall be made within a reasonable time, and for reasons (1), (2), and (4) not more than one year after the judgment, order, or proceeding was entered or taken. A motion under subdivision (b) does not affect the finality of a judgment or suspend its operation … Fed. R. Civ. P. 60(b). Similarly, Fed. R. Bankr. P. 9006(b)(1) provides: In general. Except as provided in paragraphs (2) and (3) of this subdivision, when an act is required or allowed to be done at or within a specified period by these rules or by a notice given thereunder or by order of court, the court for cause shown may at any time in its discretion (1) with or without motion or notice order the period enlarged if the request therefor is made before the expiration of the period originally prescribed or as extended by a previous order or (2) on motion made after the expiration of the specified period permit the act to be done where the failure to act was the result of excusable neglect. 3

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ANALYSIS AND APPLICATION OF LAW Fed. R. Bankr. P. 9006(b)(1) “empowers a bankruptcy court to permit a late filing if the movant’s failure to comply with an earlier deadline ‘was the result of excusable neglect.’” Pioneer Inv. Servs. v. Brunswick Assocs. Ltd. Partnership, 507 U.S. 380, 382, 113 S. Ct. 1489, 123 L. Ed. 2d 74 (1993). Excusable neglect includes both faultless omissions and omissions caused by carelessness. Id. at 388. To determine whether neglect is excusable, a court must consider all relevant circumstances surrounding the party’s omission. Id. “[T]he determination is at bottom an equitable one, taking account of all relevant circumstances surrounding the party’s omission. Id. The factors a court must consider include: (1) “the danger of prejudice to the debtor;” (2) “the length of the delay and its potential impact on judicial proceedings;” (3) “the reason for the delay, including whether it was within the reasonable control of the movant;” and (4) “whether the movant acted in good faith.” Id. The Court determined that the ordinary meaning of “neglect” necessarily contemplates inadvertence, mistake, and even carelessness. Id. The requirement, however, that the neglectful behavior also be “excusable” prevents Rule 9006(b) from, effectively, rendering deadlines open-ended and unenforceable. Id. at 395. Additionally, the Eighth Circuit Court of Appeals has stated that the Pioneer factors are not equally weighted, and that the third factor – the reason for the delay – is key. Gaydos v. Guidant Corp. (In re Guidant Corp. Implantable Defibrillators Products Liability Litigation), 496 F.3d 863, 867 (8th Cir. 2007). 4

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A. The debtor will suffer minimal prejudice if the administrative expense claim is allowed. The first Pioneer factor is the danger of prejudice to the debtor. Here, the debtor will suffer little to no prejudice if the administrative expense claim is allowed. DCC’s administrative claim in the amount of $24,903.70 is relatively small and the claim was served only six days after the March 15, 2021 deadline. The case is also in only four months old and the debtor has not yet proposed a plan. As such, the debtor will not be able to prove prejudice if the Court allows DCC’s administrative expense claim. B. There is minimal delay and allowance of the administrative expense claim will have little impact on the case. The second Pioneer factor is the length of the delay and its potential impact on judicial proceedings. DCC has already served its $24,903.70 administrative expense claim. This occurred six days after the deadline to serve such claims. Because of the short length of time between the deadline to file such claims and its actual filing, DCC asserts that there is minimal delay. Additionally, because the case is in its early stages and the debtor has not proposed a Plan, there is little to no impact on the case. As such, DCC has met its burden with respect to this Pioneer factor. C. The reason for the delay excuses the failure to comply with the Court deadline. The third Pioneer factor is the reason for the delay, including whether it was within the reasonable control of the movant. This factor should weigh in favor of DCC as it and its employees were subject to a number of issues and complications at, or near, the deadline for filing administrative expense claims. 5

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On January 1, 2021, DCC acquired UPG, which more than doubled the number of DCC’s stores, employees, and customers. The acquisition has been extremely challenging and hectic. The COVID-19 pandemic, which was near, or at its zenith at the time, made matters more difficult. (Kelsey Dec., p. 3, ¶ 16) With respect to retrieving, filing, and routing legal notices, such as bankruptcy notices, an employee of DCC collects and then scans the documents into a computer and routes the documents electronically to the appropriate email address, person, or department. The employee receiving the scanned documents renames the scanned documents, files them electronically as appropriate, and notifies other employees of the document as appropriate. (Id. at pp. 3-4, ¶¶ 18-20) On January 29, 2021, the Court’s Administrative Claim Notice was received, scanned, renamed, and filed in DCC’s computer system by Barbara Kettner, the internal audit/regional support specialist assigned to such tasks. The notice, however, was not revisited by Ms. Kettner after it had been filed in DCC’s computer per DCC’s procedures. (Kettner Dec., p. 3 ¶ 16) Ms. Kettner, unfortunately, did not know what an administrative claim in bankruptcy was, but has since become aware. (Id. at ¶ 17) Ms. Kettner has also been diagnosed with advanced lung cancer after infection from COVID-19 and began daily out-patient therapy for treatment. (Id. at p. 2 ¶¶ 7-10) Her health issues have presented physical challenges, as well as mental and emotional difficulties on a daily basis since November 2020. (Id. at ¶¶ 13) Notwithstanding the foregoing, Ms. Kettner has only missed two days of work since November 12, 2020 and stives to put in eight hours 6

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of work each workday, and, if needed, some hours on the weekend. (Kettner Dec., p. 2, ¶ 11) Still, Ms. Kettner’s health problems have had negatively affected her work and attention to detail. (Id. at ¶ 14) In addition, DCC is not normally a creditor in this type of bankruptcy case and did not know what administrative expense claims are until after the undersigned counsel was retained. Compounding the issue, Ms. Kelsey, supervisor to Ms. Kettner, was also not advised of the receipt of the Court’s Administrative Claim Notice. (Kelsey Dec., p. 4, ¶ 22) It is Ms. Kelsey’s belief that the complications and challenges related to the acquisition of UPG on January 2021, the COVID-19 pandemic, and Ms. Kettner’s health issues all contributed to the fact that the Administrative Claim Notice was neglected until March 2021. (Id. at ¶ 25) Based on the above, DCC’s delay in the filing of the administrative expense claim does not constitute a “willful flaunting of the deadline.” Had DCC not been in the midst of a huge merger with UPG, at the height of the COVID-19 pandemic, and its employees healthy, the administrative expense claims bar date would have been met. As such, this factor should weigh in favor of DCC when analyzing whether to excuse the filing delay. D. DCC has acted in good faith. The fourth Pioneer factor is whether the movant acted in good faith. The Eighth Circuit Court of Appeals has “consistently sought to distinguish between contumacious or intentional delay or disregard for deadlines and procedural rules, and a ‘marginal failure’ to meet pleading or other deadlines.” Johnson v. Dayton Elec. Mfg. Co., 140 F.3d 781, 784 (8th Cir. 1998). The delay in the filing of DCC’s administrative expense claim is not intentional or done with 7

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a disregard for deadlines and procedural rules. Prior to this case, DCC’s experience with bankruptcy was confined to ensuring that it did not violate the automatic stay. Additionally, the vast majority of DCC’s customers, of whom are businesses, very rarely file bankruptcy. (Kelsey Dec. p. 5, ¶ 28) Further, DCC has never been an active participant in a bankruptcy case and did not have in-house legal counsel until December 2020. (Id.) To ensure this sort of delay does not happen again, DCC has changed its procedures to expand the involvement of DCC’s in-house counsel with bankruptcy notices. (Id. at p. 6, ¶ 36) Lastly, upon finding out about the missed deadline, DCC immediately took steps to remedy the inadvertent error and filed its administrative expense claim six days after the deadline. As such, DCC acted in good faith and without an intentional disregard for deadlines and procedural rules. CONCLUSION Based upon the foregoing, DCC respectfully requests the Court allow its March 17, 2021 § 503(b)(9) administrative expense claim despite it having been tardily filed. Respectfully submitted, TROTT LAW, P.C. Dated: May 11, 2021 By: /e/ Samuel R. Coleman Samuel R. Coleman (#389839) Attorneys for DCC Propane, LLC 25 Dale Street North St. Paul, MN 55102 Telephone: (651) 209-9785 scoleman@trottlaw.com 8

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Chapter 11 Tea Olive I, LLC d/b/a Stock + Field, Case No.: 21-30037 Debtor. ORDER This matter is before the court on the motion of DCC Propane, LLC seeking an order for relief from the Order (I) Granting Expedited Relief and (II) Establishing Procedures for the Resolution of Reclamation Claim and Administrative Claims Asserted Pursuant to Section 503(b)(9) of the Bankruptcy Code (Doc. 54). Based upon the files and records, IT IS HEREBY ORDERED, 1. DCC Propane, LLC’s Motion is GRANTED, 2. DCC Propane, LLC’s Reclamation and/or Twenty Day Claim dated and served on March 23, 2021 is hereby deemed timely served and submitted. Dated:_______________ ____________________________________ William J. Fisher United States Bankruptcy Judge

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Chapter 11 Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037 Debtor. DECLARATION OF SAMUEL ROSS COLEMAN I, Samuel Ross Coleman, declare under penalty of perjury as follows: 1. I am the attorney at Trott Law, P.C. and represent DCC Propane, LLC (“DCC”) inthis bankruptcy case. This declaration is provided in support of the Motion Relief from Order (I) Granting Expedited Relief and (II) Establishing Procedures for the Resolution of Reclamation Claim and Administrative Claims Asserted Pursuant to Section 503(b)(9) of the Bankruptcy Code (the “Motion”). I have personal knowledge of the matters stated herein. 2. I first spoke with Eric Gibson, in-house counsel for DCC, on the morning of March15, 2021 about DCC’s involvement in this bankruptcy case. Mr. Gibson provided me the bankruptcy case number and the name of the debtor at that time. We discussed whether my firm could assist DCC with its proof of claim and take any other action to protect DCC’s interests in the case. I sent a retainer agreement to engage my firm to Mr. Gibson later that day. 3. Attached to Objection (Doc. #314) is a true and correct copy of DCC’s 20-day Claim. 4. I briefly reviewed the bankruptcy case docket on March 15th and 16th to ascertain the claims bar date and to review recent motions and orders. 1

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5. On March 17, 2021, I received the signed retainer agreement from Mr. Gibson and spent one hour of time reviewing the case docket in detail. It was during this docket review that I first discovered the Order (I) Granting Expedited Relief and (II) Establishing Procedures for the Resolution of Reclamation Claim and Administrative Claims Asserted Pursuant to Section 503(b)(9) of the Bankruptcy Code (“20-day Order”). 6. After receiving the information and documents related to DCC’s 20-day claim, I drafted and served a copy of DCC’s claim on the required parties on March 23, 2021. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief. Executed: May 11, 20211 1, 2020 /e/ Samuel R. Coleman Samuel Ross Coleman (0389839) 25 Dale Street North St. Paul, MN 55102 651-209-9785 scoleman@trottlaw.com 2

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Chapter 11 Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037 Debtor. DECLARATION OF JESSICA KELSEY I, Jessica Kelsey, declare under penalty of perjury as follows: 1. I am the Operations Accounting Manager at DCC Propane, LLC (“DCC”). This declaration is provided in support of the Motion Relief from Order (I) Granting Expedited Relief and (II) Establishing Procedures for the Resolution of Reclamation Claim and Administrative Claims Asserted Pursuant to Section 503(b)(9) of the Bankruptcy Code (the “Motion”). 2. As part of my job responsibilities at DCC, I have personal knowledge of and am familiar with the operations, policies, and procedures of DCC discussed below. 3. I have been an employee of DCC since August 2009 and the Operations Accounting Manager of DCC since August 2011. 4. My job duties as Operations Accounting Manager include, but are not limited to, oversight of the field accounting operations for 135 retail locations, process development, oversight of the training of new field accounting staff, acquisition due diligence, acquisition integration, systems support and maintenance initiatives, business licensing, direct oversight of a 1

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Regional Accounting team that supports the field accounting staff, interviewing, and hiring of field accounting staff for 50 of the locations. 5. I currently supervise 9 employees directly and approximately 200 employees indirectly. 6. As part of its core business, DCC sells propane to customers, such as the debtor, who in turn resell the propane to retail customers. 7. DCC operates under the name DCC Propane, LLC and under the assumed names of Hicksgas and Liberty Propane. 8. As part of its business, DCC enters into lease agreements with its customers for the lease of DCC’s propane dispensing units and propane storage tanks. The propane dispensing units and tanks are stored at the customers’ retail stores and used by the customer to fill propane cylinders for resale. DCC refills the propane storage tanks with propane as requested by the customer. The customer is sent an invoice for the propane delivered. 9. The debtor entered into and is currently bound by leases through Hicksgas for propane dispensing units located at eleven of the debtor’s store locations and a lease through Liberty Propane for a propane dispensing at one of the debtor’s store locations. 10. Between December 24, 2020 and January 10, 2021, DCC delivered propane and propane cylinders to seven of the debtor’s stores on 22 occasions, resulting in a total charge of $24,903.70. 11. The propane and propane cylinders delivered from December 24, 2020 to January 10, 2021 constitute goods sold within 20 days of the debtor’s bankruptcy filing. 2

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12. On January 1, 2021, United Propane Gas (“UPG”) was acquired by and became a part of DCC. DCC’s acquisition of UPG more than doubled the number of DCC’s stores, employees, and customers. 13. As part of my job duties after the acquisition of UPG, I was tasked with integrating the administrative and accounting aspects of UPG with DCC. 14. Integrating the operations, policies and procedures of UPG and DCC was extremely challenging and hectic. It took approximately three months –from January 1, 2021 through March 2021— for me to achieve a modicum of stability in my daily work. 15. During the first months of merger, much of my work involved triaging the immediate needs and operations of the company while simultaneously working to assign new roles for employees and implementing new policies and procedures. 16. The COVID-19 pandemic, which was near or at its zenith in terms of case-counts and deaths in the early part of 2021, made matters more difficult. 17. One of my duties since September 2020 is oversight of the employee who is performing the bankruptcy notice review involving bankruptcy cases that are filed by or against our customers. One of those customers was the debtor. 18. With respect to retrieving, filing, and routing legal notices such as bankruptcy notices, DCC has followed the process below since approximately September 2020. 19. Mail delivered to DCC’s local post office boxes is regularly collected by an employee. The employee then scans the documents into a computer and routes the documents electronically to the appropriate email address, person or department. The employee receiving the 3

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scanned documents renames the scanned documents, files them electronically as appropriate, and notifies other employees of the document as appropriate. 20. Barbara Kettner, who is an internal audit/regional support specialist at DCC and works under me, is responsible for the initial review of bankruptcy notices received by DCC since September of 2020, and had no prior experience with bankruptcies in any way. 21. The letter from the law firm, Fredrikson & Byron, P.A. dated January 22, 2021 (Doc. 86, Ex. 1), claim form (Doc. 86, Ex. 2), and Order (I) Granting Expedited Relief and (II) Establishing Procedures for the Resolution of Reclamation Claims and Administrative Claims Asserted Pursuant to Section 503(b)(9) of the Bankruptcy Code (Doc. 54) (collectively, the “Administrative Claim Notice”) were received, scanned, renamed and filed in DCC’s computer system on January 29, 2021. 22. I did not know what an administrative claim in a bankruptcy case was until after outside counsel was retained, nor did I have knowledge of the receipt of the Administrative Claim Notice. 23. Barbara Kettner, who is a key employee, has suffered a series of health issues since November 2020. 24. The Administrative Claim Notice was left unaddressed once it was filed in DCC’s computer system until late March. 25. The complications and challenges related to the acquisition of UPG on January 1, 2021, the COVID-19 pandemic, and Barbara Kettner’s health issues all contributed to the fact that the Administrative Claim Notice was neglected until March of 2021. 4

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26. I understand that DCC’s outside counsel, Samuel R. Coleman, served a copy of DCC’s completed 20-claim Form on the appropriate parties on March 23, 2021. 27. For context in understanding how DCC reviews bankruptcy notices, DCC’s primary objective after receiving bankruptcy notices is to ensure that any dunning letters, invoices, statements, demands for payment or the like are not sent to a bankruptcy debtor. The primary objective is to take timely action to ensure that DCC does not violate the automatic stay. 28. In my time as an employee at DCC, I am not aware of DCC ever having been actively involved in a bankruptcy case as a creditor. DCC is rarely involved in bankruptcy cases because its customers, the vast majority of whom are businesses, very rarely file for bankruptcy. 29. DCC typically does not file proofs of claim because unpaid debts have historically been insignificant and DCC rarely has secured claims to assert. 30. Because the unsecured debt in this case is not an insignificant amount, my department paid greater attention to the debtor’s bankruptcy case beginning on approximately March 1, 2021 when we involved our in-house counsel who was acquired with the UPG staff who joined DCC on December 30, 2020. 31. Because the debtor’s bankruptcy case had just been filed on January 10, 2021, we believed we had ample time to review the debtor’s account, retain counsel, and take necessary steps to protect DCC’s rights and interests. 32. After discussions internally, a decision was made to retain outside counsel. 33. Upon information and belief, our in-house counsel first spoke with attorney Samuel R. Coleman about this bankruptcy case on the morning of March 15, 2021. 5

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4-27-2021

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Chapter 11 Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037 Debtor. DECLARATION OF BARBARA KETTNER I, Barbara Kettner, declare under penalty of perjury as follows: 1. I am an employee of DCC Propane, LLC (“DCC”) and work as an internal audit/regional support specialist. This declaration is provided in support of the Motion Relief from Order (I) Granting Expedited Relief and (II) Establishing Procedures for the Resolution of Reclamation Claim and Administrative Claims Asserted Pursuant to Section 503(b)(9) of the Bankruptcy Code (the “Motion”). 2. As part of my job responsibilities at DCC, I have personal knowledge of and am familiar with the operations, policies, and procedures of DCC discussed below. 3. I have been an employee of DCC since September 29, 1997 and in the role of an internal audit/regional support since August 6,2020. 4. I do not have extensive experience with bankruptcy law and procedure. 5. Since September 2020, in addition to my existing duties, I have taken on the task of reviewing scanned mail related to customer bankruptcy filings. I receive the scanned 1

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documents through a dedicated email address for bankruptcy notices, rename the file, and file the documents in an electronic folder on DCC’s computer system. 6. When DCC acquired United Propane Gas (“UPG”) as of January 1, 2021, the number of locations and customers I dealt with regularly increased dramatically. 7. On November 12, 2020, I was diagnosed with COVID-19 and was ill for several days. I was cleared of the COVID-19 infection on November 23, 2020. 8. During a medical examination related to my COVID-19 infection, I was diagnosed with advanced lung cancer. 9. On December 30, 2020, I began a series of tests and procedures relating to my cancer diagnosis. 10. Beginning on February 18, 2021, I began daily out-patient therapy for treatment of my cancer. 11. I have only missed two days of work since November 12, 2020. I have strived to put in eight hours of work each workday. If needed, I have worked some hours on the weekend. 12. The recent acquisition of UPG and my health issues have made my work more challenging, particularly the period from November 2020 through April 6, 2021. 13. My health issues have presented physical challenges, as well as mental and emotional difficulties, on a daily basis since November 2020. 14. While I believe the quality of my work and attention to detail has remained and continues to be satisfactory, I believe that the recent challenges described in this affidavit have had a negative affect at times. 2

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15. The letter from the law firm, Fredrikson & Byron, P.A. dated January 22, 2021 (Doc. 86, Ex. 1), claim form (Doc. 86, Ex. 2), and the Order (I) Granting Expedited Relief and (II) Establishing Procedures for the Resolution of Reclamation Claims and Administrative Claims Asserted Pursuant to Section 503(b)(9) of the Bankruptcy Code (Doc. 54) (collectively, the “Administrative Claim Notice”) were received by me, renamed and filed in DCC’s computer system on January 29, 2021. 16. I did not revisit the Administrative Claim Notice after I filed it in DCC’s computer system per the procedures that were set for me to follow by my supervisor. 17. I did not know what administrative claims in bankruptcy cases were until the last several days or so. 18. I did not read the Administrative Claim Notice until the last several days or so. I have had no training or knowledge of what to do with any of these items. 19. As instructed by my supervisor, my primary objective in dealing with bankruptcy notices was to take such actions to ensure that DCC was not sending demands for payment to customers who had filed for bankruptcy. 20. Since I have been an employee of DCC, I am not aware of DCC ever being actively involved in a bankruptcy case as a creditor. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief. 3

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DaunraC7 Executed: April 27, 2021 Barbara Kettner

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