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Full title: Affidavit (re:327 Motion to sell property free and clear of liens) filed by Tea Olive I, LLC. (Kinsella, Steven) (Entered: 06/07/2021)

Document posted on Jun 6, 2021 in the bankruptcy, 2 pages and 0 tables.

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DECLARATION OF STEVEN R. KINSELLA IN SUPPORT OF AMENDED MOTION FOR AN ORDER APPROVING SALE OF CLAIMS FREE AND CLEAR OF LIENS AND INTERESTS Steven R. Kinsella makes the following declaration in support of the Amended Motion for an Order Approving Sale of Claims Free and Clear of Liens and Interests [Docket No.On May 18, 2021, the Debtor filed the Motion seeking approval of the sale of its rights, titles, and interests in, to, and under any and all claims, demands, rights and causes of action that the Debtor had, now has, or may in the future against or with respect to a settlement of claims or judgment (the “Claims”) in that certain class action proceeding against Visa, Inc. MasterCard, Inc. and certain other defendants in the case captioned as In re: Payment Card Interchange Fee and Merchant Discount Antitrust Litig.After the Motion was filed, on June 1, 2021, the Debtor’s counsel was made aware of other parties that expressed interest in purchasing the claims for more than the Original Sale Price.The Debtor asked the interested parties and the Original Purchaser to make a best and final offer to purchase the Claims by 11:00 am CST on Monday, June 7, 2021.The Debtor intends to seek approval of a new purchase agreement and the sale of the Claims to the New Purchaser for $83,000 at the hearing scheduled for June 8, 2021, at 9:45 am CST.

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037 Chapter 11 Case Debtor. DECLARATION OF STEVEN R. KINSELLA IN SUPPORT OF AMENDED MOTION FOR AN ORDER APPROVING SALE OF CLAIMS FREE AND CLEAR OF LIENS AND INTERESTS Steven R. Kinsella makes the following declaration in support of the Amended Motion for an Order Approving Sale of Claims Free and Clear of Liens and Interests [Docket No. 327] (the “Motion”). 1. I am a shareholder in the law firm of Fredrikson & Byron, P.A. (“Fredrikson”), chapter 11 counsel for Tea Olive I, LLC d/b/a Stock+Field (the “Debtor”). 2. On May 18, 2021, the Debtor filed the Motion seeking approval of the sale of its rights, titles, and interests in, to, and under any and all claims, demands, rights and causes of action that the Debtor had, now has, or may in the future against or with respect to a settlement of claims or judgment (the “Claims”) in that certain class action proceeding against Visa, Inc. MasterCard, Inc. and certain other defendants in the case captioned as In re: Payment Card Interchange Fee and Merchant Discount Antitrust Litig., Case No 05-1720 (E.D.N.Y.) (the “Class Action Case”). In the Motion, the Debtor proposed to sell the Claims to Haybeach Special Opportunities Fund, LP (the “Original Purchaser”) for a total amount of $61,500.

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3. After the Motion was filed, on June 1, 2021, the Debtor’s counsel was made aware of other parties that expressed interest in purchasing the claims for more than the Original Sale Price. 4. The Debtor asked the interested parties and the Original Purchaser to make a best and final offer to purchase the Claims by 11:00 am CST on Monday, June 7, 2021. 5. The Debtor ultimately received two offers. The Original Purchaser increased its offer to $71,000 and LW BMC I, managed by Lake Whillans Capital Partners, LCC (the “New Purchaser”) made an offer of $83,000. 6. After reviewing the two offers, the Debtor informed the parties that it would be accepting the New Purchaser’s offer. 7. The Debtor intends to seek approval of a new purchase agreement and the sale of the Claims to the New Purchaser for $83,000 at the hearing scheduled for June 8, 2021, at 9:45 am CST. 8. If possible, the Debtor will file the new purchase agreement prior to the hearing. The Debtor does not anticipate that the new purchase agreement will be substantially different than the purchase agreement with the Original Purchaser filed with the Court. I declare under penalty of perjury that the foregoing is true and correct according to the best of my knowledge, information, and belief. Dated: June 7, 2021 /e/ Steven R. Kinsella Steven R. Kinsella

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