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Full title: Ex Parte Motion to Extend [Exceed Maximum Page Limit]. filed by Garland S. Cassada on behalf of DBMP LLC. (Cassada, Garland)

Document posted on Nov 4, 2021 in the bankruptcy, 6 pages and 0 tables.

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DEBTOR’S EX PARTE MOTION REQUESTING AUTHORITY TO EXCEED MAXIMUM PAGE LIMIT DBMP LLC, the debtor and debtor in possession in the above-captioned chapter 11 case (the “Debtor”), files this ex parte Motion requesting authority to exceed the page limit established for briefs filed pursuant to Rule 9013-2(a) of the Rules of Practice and Procedure of the United States Bankruptcy Court for the Western District of North Carolina (the “Local Rules”), and in support thereof respectfully states as follows: 1. Contemporaneously herewith, the Debtor will file its Reply to Informational Brief of Official Committee of Asbestos Personal Injury Claimants (the “Reply to ACC Informational Brief”).The Reply to ACC Informational Brief is 41 pages, exclusive of the signature page and any exhibits, and hence is 10 pages shorter than the ACC Informational Brief to which it responds. Conclusion WHEREFORE, the Debtor respectfully requests the Court enter the Proposed Order authorizing the Debtor to exceed the page limit imposed by Local Rule 9013-2(a) with respect to the Reply to ACC Informational Brief.According to the Motion, the Debtor will file in response to the ACC Informational Brief its Reply to Informational Brief of Official Committee of Asbestos Personal Injury Claimants (the “Reply to ACC Informational Brief”), which will exceed the 25-page limit established by Rule 9013-2(a) of the Rules of Practice and Procedure of the United States Bankruptcy Court for the Western District of North Carolina (the “Local Rules”).

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UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION In re Chapter 11 DBMP LLC,1 Case No. 20-30080 (JCW) Debtor. DEBTOR’S EX PARTE MOTION REQUESTING AUTHORITY TO EXCEED MAXIMUM PAGE LIMIT DBMP LLC, the debtor and debtor in possession in the above-captioned chapter 11 case (the “Debtor”), files this ex parte Motion requesting authority to exceed the page limit established for briefs filed pursuant to Rule 9013-2(a) of the Rules of Practice and Procedure of the United States Bankruptcy Court for the Western District of North Carolina (the “Local Rules”), and in support thereof respectfully states as follows: 1. On August 23, 2021, the Official Committee of Asbestos Personal Injury Claimants (the “Committee”) filed the Informational Brief of the Official Committee of Asbestos Personal Injury Claimants of DBMP LLC (Dkt. 1003) (the “ACC Informational Brief”). 2. The ACC Informational Brief is 51 pages long (excluding the final signature page and exhibits). On request of the Committee, the Court entered an ex parte order permitting the Committee to file the ACC Informational Brief (and certain other papers) in excess of the otherwise applicable 25-page limit in Local Rule 9013-2(a) (Dkt. 1013). 1The last four digits of the Debtor’s taxpayer identification number are 8817. The Debtor’s address is 20 Moores Road, Malvern, Pennsylvania 19355.

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3. Contemporaneously herewith, the Debtor will file its Reply to Informational Brief of Official Committee of Asbestos Personal Injury Claimants (the “Reply to ACC Informational Brief”). Relief Requested 4. By this Motion, the Debtor seeks authority to exceed the 25-page limit for briefs established pursuant to Local Rule 9013-2(a). Attached hereto as Exhibit A is a proposed order granting the relief requested in this Motion (the “Proposed Order”). 5. Local Rule 9013-2(a) establishes a 25-page limit for briefs. Additional pages beyond the 25-page limit are necessary for the Debtor to adequately respond to the numerous factual assertions made in the ACC Informational Brief, which itself exceeds the 25-page limit by over 25 pages. The Reply to ACC Informational Brief is 41 pages, exclusive of the signature page and any exhibits, and hence is 10 pages shorter than the ACC Informational Brief to which it responds. Accordingly, good cause exists to permit the Debtor to exceed the 25-page limit. Conclusion WHEREFORE, the Debtor respectfully requests the Court enter the Proposed Order authorizing the Debtor to exceed the page limit imposed by Local Rule 9013-2(a) with respect to the Reply to ACC Informational Brief. Dated: November 5, 2021 Respectfully submitted, Charlotte, North Carolina /s/ Garland S. Cassada Garland S. Cassada (NC Bar No. 12352) Richard C. Worf, Jr. (NC Bar No. 37143) ROBINSON, BRADSHAW & HINSON, P.A. 101 North Tryon Street, Suite 1900 Charlotte, North Carolina 28246 Telephone: (704) 377-2536 Facsimile: (704) 378-4000

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E-mail: gcassada@robinsonbradshaw.com rworf@robinsonbradshaw.com Gregory M. Gordon (TX Bar No. 08435300) JONES DAY 2727 North Harwood Street, Suite 500 Dallas, Texas 75201 Telephone: (214) 220-3939 Facsimile: (214) 969-5100 E-mail: gmgordon@jonesday.com (Admitted pro hac vice) Jeffrey B. Ellman (GA Bar No. 141828) JONES DAY 1221 Peachtree Street, N.E., Suite 400 Atlanta, Georgia 30361 Telephone: (404) 581-3939 Facsimile: (404) 581-8330 E-mail: jbellman@jonesday.com (Admitted pro hac vice) Elizabeth Runyan Geise Valerie E. Ross SCHIFF HARDIN LLP 901 K Street NW, Suite 700 Washington, DC 20001 Telephone: (202) 778-6400 Facsimile: 202.778.6460 E-mail: egiese@schiffhardin.com vross@schiffhardin.com (Admitted pro hac vice) ATTORNEYS FOR DEBTOR AND DEBTOR IN POSSESSION

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EXHIBIT A

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UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION In re Chapter 11 DBMP LLC,1 Case No. 20-30080 (JCW) Debtor. ORDER AUTHORIZING DEBTOR TO EXCEED MAXIMUM PAGE LIMIT This matter came before the Court on the Debtor’s Ex Parte Motion Requesting Authority to Exceed Page Limit (the “Motion”), filed by DBMP LLC, the debtor and debtor in possession in the above-captioned chapter 11 case (“the Debtor”). According to the Motion, the Debtor will file in response to the ACC Informational Brief its Reply to Informational Brief of Official Committee of Asbestos Personal Injury Claimants (the “Reply to ACC Informational Brief”), which will exceed the 25-page limit established by Rule 9013-2(a) of the Rules of Practice and Procedure of the United States Bankruptcy Court for the Western District of North Carolina (the “Local Rules”). Based on the Motion, the Court finds and concludes that good cause exists to grant relief from the 25-page limit imposed by Local Rule 9013-2(a), to the extent that it applies to the Reply 1The last four digits of the Debtor’s taxpayer identification number are 8817. The Debtor’s address is 20 Moores Road, Malvern, Pennsylvania 19355.

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to ACC Informational Brief. Accordingly, the Motion is GRANTED and the page limit established by Local Rule 9013-2(a) is hereby lifted with respect to the Objection. This Order has been signed United States Bankruptcy Court electronically. The judge’s signature and court’s seal appear at the top of the Order.

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