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Full title: Document re: Letter to The Honorable Michael B. Kaplan (related document:[843] Motion to Appoint Examiner filed by U.S. Trustee U.S. Trustee, [982] Document filed by Creditor Committee Official Committee of Talc Claimants) filed by Paul R. DeFilippo on behalf of LTL Management LLC. (DeFilippo, Paul)

Document posted on Dec 28, 2021 in the bankruptcy, 2 pages and 0 tables.

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United States Bankruptcy Court, District of New Jersey Trenton, NJ 08608 Re: LTL Management LLC, Case No. 21-30589 (MBK) The Debtor disclosed the salient facts regarding that restructuring in its first day filings, and the restructuring was the subject of extensive discovery in connection with the Debtor’s requests regarding the automatic stay and the issuance of a preliminary injunction. Further, although duplicative, the Talc Claimants’ Committee (the “TCC”) and other parties have been and are engaged in extensive discovery regarding the restructuring and other issues in connection with the pending motions to dismiss. Respectfully submitted, /s/

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2727 NORTH HARWOOD STREET • DALLAS, TEXAS 75201.1515 TELEPHONE: +1.214.220.3939 • FACSIMILE: +1.214.969.5100 Direct Number: (214) 969-3759 gmgordon@jonesday.com December 29, 2021 The Honorable Michael B. Kaplan United States Bankruptcy Court, District of New Jersey Clarkson S. Fisher US Courthouse 402 East State Street, Courtroom #8 Trenton, NJ 08608 Re: LTL Management LLC, Case No. 21-30589 (MBK) Dear Judge Kaplan: This responds to Arnold & Itkin LLP’s request for an adjournment of the January 11, 2022 hearing on the motion of the United States Trustee for the appointment of an examiner. The Debtor respectfully submits that an adjournment is not warranted. The examiner motion can be decided now and should be denied without delay. As will be described more fully in its objection to the examiner motion, the appointment of an examiner is neither necessary nor appropriate. The asserted rationale for an examiner—to discover facts surrounding the prepetition corporate restructuring that are allegedly relevant to the pending motions to dismiss—is unfounded. The Debtor disclosed the salient facts regarding that restructuring in its first day filings, and the restructuring was the subject of extensive discovery in connection with the Debtor’s requests regarding the automatic stay and the issuance of a preliminary injunction. Further, although duplicative, the Talc Claimants’ Committee (the “TCC”) and other parties have been and are engaged in extensive discovery regarding the restructuring and other issues in connection with the pending motions to dismiss. And that discovery is incremental to the myriad other discovery the TCC is seeking in furtherance of its announced quest to object to virtually every aspect of this case. For these reasons and others, the appointment of an examiner would be duplicative and wasteful and would only delay the case. Because there is no need for the appointment of an examiner, there is likewise no need or reason to adjourn the hearing on the examiner motion. AMSTERDAM • ATLANTA • BEIJING • BOSTON • BRISBANE • BRUSSELS • CHICAGO • CLEVELAND • COLUMBUS • DALLAS • DETROIT DUBAI • DÜSSELDORF • FRANKFURT • HONG KONG • HOUSTON • IRVINE • LONDON • LOS ANGELES • MADRID • MELBOURNE

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December 29, 2021 Page 2 Thank you for your consideration of this letter. Respectfully submitted, /s/ Gregory M. Gordon/JNL Gregory M. Gordon

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