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Full title: Notice of Revised Proposed Order on Trustee's Motion for Authority (a) to Pay All Remaining Pre-Closing PACA Claims from the PACA Escrow Reserve, (b) to Release any Remaining Escrowed Funds in the PACA Escrow Reserve to the Trustee, (c) to Expunge all Other PACA Claims and (d) for Related Relief. (Related document(s):[915] Generic Motion) Filed by Janet S Casciato-Northrup (Attachments: # (1) Master Service List # (2) Service List of Unpaid Debts per Docket No. 761 # (3) Service List of Known PACA Vendors # (4) Proposed Order) (McIntyre, Heather)

Document posted on Sep 23, 2021 in the bankruptcy, 5 pages and 0 tables.

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Jointly Administered NOTICE OF REVISED PROPOSED ORDER ON TRUSTEE’S MOTION FOR AUTHORITY (A) TO PAY ALL REMAINING PRE-CLOSING PACA CLAIMS FROM THE PACA ESCROW RESERVE, (B) TO RELEASE ANY REMAINING ESCROWED FUNDS IN THE PACA ESCROW RESERVE TO THE TRUSTEE, (C) TO EXPUNGE ALL OTHER PACA CLAIMS915-5 (the “Original Proposed Order”) attaching at Exhibit 1 thereto a list of Remaining Unpaid PACA Claims (the “Original Remaining Unpaid PACA Schedule”).Country Fresh Holding Company Inc. (7822); Country Fresh Midco Corp. (0702); Country Fresh Acquisition Corp. (5936); Country Fresh Holdings, LLC (7551); Country Fresh LLC (1258); Country Fresh Dallas, LLC (7237); Country Fresh Carolina, LLC (8026);Country Fresh Midwest, LLC (0065); Country Fresh Orlando, LLC (7876); Country Fresh Transportation LLC (8244) CF Products, LLC (8404) Country Fresh Manufacturing, LLC (7839); Champlain Valley Specialty of New York, Inc. (9030); Country Fresh Pennsylvania, LLC (7969); Sun Rich Fresh Foods (NV) Inc. (5526); Sun Rich Fresh Foods (USA) Inc. (0429); and Sun Rich Fresh Foods (PA) Inc. (4661). parties listed on the attached Service List of Unpaid Debts per Docket No. 761 via first-class, U.S. mail, postage prepaid to the extent not served via ECF; and (iv) parties listed on the attached Service List of Known PACA Vendors via first-class, U.S. mail, postage prepaid to the extent not served via ECF.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION IN RE: § § Case No.: 21-bk-30574 COUNTRY FRESH HOLDING § COMPANY, INC., et. al.1 § Chapter 7 § Debtors. § Jointly Administered NOTICE OF REVISED PROPOSED ORDER ON TRUSTEE’S MOTION FOR AUTHORITY (A) TO PAY ALL REMAINING PRE-CLOSING PACA CLAIMS FROM THE PACA ESCROW RESERVE, (B) TO RELEASE ANY REMAINING ESCROWED FUNDS IN THE PACA ESCROW RESERVE TO THE TRUSTEE, (C) TO EXPUNGE ALL OTHER PACA CLAIMS AND (D) FOR RELATED RELIEF (Related to Dkt. No. 915) PLEASE TAKE NOTICE that, on September 2, 2021, Janet S. Northrup, the Chapter 7 Trustee (the “Trustee”) of the bankruptcy estate of Country Fresh Holding Company, Inc et. al. (the “Debtors”) filed her Trustee’s Motion to for Authority (A) to Pay All Remaining Pre-Closing PACA Claims from the PACA Escrow Reserve, (B) to Release Any Remaining Escrowed Funds in the PACA Escrow Reserve to the Trustee, (C) to Expunge All Other PACA Claims and (D) for Related Relief [Dkt. No. 915] (the “PACA Motion”), which was filed with a proposed order at Docket No. 915-5 (the “Original Proposed Order”) attaching at Exhibit 1 thereto a list of Remaining Unpaid PACA Claims (the “Original Remaining Unpaid PACA Schedule”). Since the filing of the PACA Motion, one PACA invoice was paid pursuant to the Stipulation and Agreed 1 The Debtors in these Chapter 7 cases and the last four digits of each Debtors’ taxpayer identification number are as follows: Country Fresh Holding Company Inc. (7822); Country Fresh Midco Corp. (0702); Country Fresh Acquisition Corp. (5936); Country Fresh Holdings, LLC (7551); Country Fresh LLC (1258); Country Fresh Dallas, LLC (7237); Country Fresh Carolina, LLC (8026); Country Fresh Midwest, LLC (0065); Country Fresh Orlando, LLC (7876); Country Fresh Transportation LLC (8244) CF Products, LLC (8404) Country Fresh Manufacturing, LLC (7839); Champlain Valley Specialty of New York, Inc. (9030); Country Fresh Pennsylvania, LLC (7969); Sun Rich Fresh Foods (NV) Inc. (5526); Sun Rich Fresh Foods (USA) Inc. (0429); and Sun Rich Fresh Foods (PA) Inc. (4661). The Debtors’ principal place of business is 3200 Research Forest Drive, Suite A5, The Woodlands, TX, 77381.

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Order Regarding Release of Escrowed Fund by CitiBank, N.A. to Buyer [Dkt. No. 928] (the “Escrow Release Stipulation”) entered on September 7, 2021. PLEASE TAKE FURTHER NOTICE that no objection or other response to the PACA Motion was timely filed by any party. As a result, the Trustee now submits a revised proposed order with this Notice (the “Revised Proposed Order”) that revises the Remaining Unpaid PACA Claims to reflect all payments made pursuant to the Escrow Release Stipulation. Further, attached hereto as Exhibit A is a version of Original Remaining Unpaid PACA Schedule whereby all cells changed as compared between the Original Proposed Order and the Revised Proposed Order are highlighted. Dated: September 24, 2021. Respectfully submitted, /s/ Heather Heath McIntyre Wayne Kitchens TBN 11541110 wkitchens@hwa.com Heather McIntyre TBN 24041076 hmcintyre@hwa.com HUGHESWATTERSASKANASE, LLP Total Plaza 1201 Louisiana, 28th Floor Houston, Texas 77002 Telephone: (713) 759-0818 Facsimile: (713) 759-6834 ATTORNEYS FOR JANET S. NORTHRUP, CHAPTER 7 TRUSTEE

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CERTIFICATE OF SERVICE The undersigned hereby certifies that on September 24, 2021, a true and correct copy of the foregoing document has been served on (i) parties receiving ECF notice via ECF in the above-referenced case, and (ii) parties listed on the attached Master Service List via first-class, U.S. mail, postage prepaid to the extent not served via ECF; and (iii) parties listed on the attached Service List of Unpaid Debts per Docket No. 761 via first-class, U.S. mail, postage prepaid to the extent not served via ECF; and (iv) parties listed on the attached Service List of Known PACA Vendors via first-class, U.S. mail, postage prepaid to the extent not served via ECF. /s/ Heather Heath McIntyre Heather Heath McIntyre

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EXHIBIT A

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Country Fresh Bankruptcy Petition #: 21-30574 Remaining Unpaid PACA Schedule Unpaid Invoice Interest Rate Vendor Interest Amount 80% Attorneys Fees Total Total (Annual) A Plus Growers $ 17,824.80 $ 12,822.09 4.50% $ - $ 30,646.89Amazon Prod. Network - 6,489.40 contract rate 11,849.83 18,339.23Ayco Farms 10,317.60 - - 10,317.60C. Lane Company, LLC 5,300.00 14,426.47 contract rate 32,799.60 52,526.07C.H. Robinson - 20,765.64 contract rate 36,520.92 57,286.56CarbAmericas Inc. - 11,666.70 contract rate 24,516.37 36,183.07Citrus Plus, Inc. 10,162.90 6,426.63 contract rate 7,140.20 23,729.73Continental Fresh, LLC - 3,381.50 4.50% - 3,381.50Custom Produce Sales 51,315.69 57,677.33 contract rate 25,130.06 134,123.08Diamond Onions Inc. 326.56 - -Eagle Produce 3,816.51 4,605.29 contract rate 1,852.93 10,274.73Freshouse II, LLC - 437.78 contract rate 1,625.19 2,062.97FreshPoint Central Fla., Inc. - 567.31 contract rate 5,061.13 5,628.44Fyffes North American - 2,798.20 contract rate 39,216.12 42,014.32Grimmway 2,720.00 - contract rate 889.21 3,609.21JA Pacific 67,095.59 29,604.37 4.50% - 96,699.96Kapi Kapi Growers, Inc. - 5,714.12 contract rate - 5,714.12Kingston Produce 13,760.00 - - 13,760.00Loomis Distributing, Inc. - 2,703.02 contract rate 2,409.12 5,112.14Midwest Best Produce 92,359.15 1,558.56 4.50% - 93,917.71Nickey Gregory 9,842.20 1,324.26 contract rate 6,770.51 17,936.97Oppeheimer - 12,224.28 contract rate 7,844.42 20,068.70Pacific Trellis 13,500.00 286.27 contract rate - 13,786.27Panorama 33,591.60 - none 35,893.46 69,485.06Pete Pappas Sales, Inc. - 33.78 contract rate 5,197.95 5,231.73Pura Vida - 2,190.01 4.50% 1,854.14 4,044.15S & S Marketing 812.80 17,616.35 contract rate 30,494.80 48,923.95Sol Grp. Mrkt. - 4,135.14 4.50% - 4,135.14Stella Farms LLC 18,590.82 7,068.56 contract rate 36,204.66 61,864.04TMC Prod. Sols. Corp. - 4,964.03 contract rate 21,283.75 26,247.78Wm. Bolthouse Farms 6,425.00 - - 6,425.00Total $ 357,761.22 $ 231,487.09 $ 334,554.39 $ 923,476.14

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