mew Doc 2607 Filed 02/20/18 Entered 02/20/18 19:03:23 Main Document Pg 1 of 37

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1 Pg 1 of 37 HEARING DATE AND TIME: March 27, 2018 at 11:00 a.m. (Eastern Time) RESPONSE DEADLINE: March 20, 2018 at 4:00 p.m. (Eastern Time) THE ATTACHED OMNIBUS OBJECTION TO CLAIMS SEEKS TO RECLASSIFY CERTAIN FILED PROOFS OF CLAIM. PLEASE CAREFULLY REVIEW THE ATTACHED OBJECTION AND THE ATTACHMENTS THERETO TO DETERMINE WHETHER THE OBJECTION AFFECTS ANY CLAIM(S) YOU MAY HAVE FILED. IF YOU HAVE QUESTIONS, PLEASE CONTACT DEBTORS COUNSEL, OLGA F. PESHKO, AT UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK x In re : Chapter 11 : WESTINGHOUSE ELECTRIC COMPANY : Case No (MEW), et al., : : : Debtors. 1 : (Jointly Administered) : x NOTICE OF DEBTORS SEVENTH OMNIBUS OBJECTION TO CLAIMS ( ) PLEASE TAKE NOTICE that on February 20, 2018, Westinghouse Electric Company ( WEC ) and certain of its affiliates, as debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the Debtors ) filed the annexed Seventh Omnibus Objection to (the Objection ), pursuant to sections 105(a) and 502(b) of title 11 of the United States Code (the Bankruptcy Code ). A hearing on the relief requested in the Objection has been requested on March 27, 2018 at 11:00 a.m. (Eastern Time) (the Hearing ) before the Honorable Michael E. Wiles in the United States Bankruptcy Court for the Southern District of New York, located at One Bowling Green, New York, New York (the Bankruptcy Court ). 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, if any, are: Westinghouse (0933), CE Nuclear Power International, (8833), Fauske and Associates (8538), Field Services, (2550), Nuclear Technology Solutions (1921), PaR Nuclear Holding Co., (7944), PaR Nuclear, (6586), PCI Energy Services (9100), Shaw Global Services, (0436), Shaw Nuclear Services, (6250), Stone & Webster Asia (1348), Stone & Webster Construction (1673), Stone & Webster International (1586), Stone & Webster Services (5448), Toshiba Nuclear Energy Holdings (UK) Limited (N/A), TSB Nuclear Energy Services (2348), WEC Carolina Energy Solutions, (8735), WEC Carolina Energy Solutions, (2002), WEC Engineering Services (6759), WEC Equipment & Machining Solutions, (3135), WEC Specialty (N/A), WEC Welding and Machining, (8771), WECTEC Contractors (4168), WECTEC Global (8572), WECTEC (6222), WECTEC Staffing Services (4135), Westinghouse Energy Systems (0328), Westinghouse Industry Products International Company (3909), Westinghouse International Technology (N/A), and Westinghouse Technology Licensing Company (5961). The Debtors principal offices are located at 1000 Westinghouse Drive, Cranberry Township, Pennsylvania WEIL:\ \1\

2 Pg 2 of 37 The Objection requests that the Bankruptcy Court reclassify one or more claims listed on Exhibit 1 to the Proposed Order, which is attached as Exhibit A to the Objection, on the ground that such claim or claims are not entitled to secured status because they are not secured by a lien on property in which the Debtors estates have an interest. If you filed the applicable proof of claim and you do NOT oppose the reclassification of your claim(s) as specified on Exhibit 1, then you do NOT need to file a written response to the Objection and you do NOT need to appear at the hearing. If you filed the applicable proof of claim and you DO oppose the reclassification of your claim(s) listed on Exhibit 1 then you MUST file with the Court and serve on the parties listed below a written response ( Response ) to the Objection that is received on or before 4:00 p.m. Eastern Time on March 20, 2018 (the Response Deadline ). Any Response must contain at a minimum the following: (i) a caption setting forth the name of the Bankruptcy Court, the names of the Debtors, the case number and the title of the Objection to which the response is directed; (ii) the name of the claimant and description of the basis for the amount of the claim; (iii) a concise statement setting forth the reasons why the claim should not be disallowed, expunged, reduced, or reclassified for the reasons set forth in the Objection, including, but not limited to, the specific factual and legal bases which will be relied upon in opposing the Objection; (iv) all documentation or other evidence of the claim, to the extent not included with the proof of claim previously filed with the Bankruptcy Court, which will be relied upon in opposing the Objection; (v) the address(es) to which the Debtors must return any reply to a Response, if different from that presented in the proof of claim; and (vi) the name, address, and telephone number of the person (which may be the claimant or a legal representative) possessing ultimate authority to reconcile, settle, or otherwise resolve the claim on behalf of the claimant. Any Response to the Motion must be in writing, shall conform to the Federal Rules of Bankruptcy Procedure and the Local Bankruptcy Rules, and shall be filed with the Bankruptcy Court (a) by attorneys practicing in the Bankruptcy Court, including attorneys admitted pro hac vice, electronically in accordance with General Order M-399 (which can be found at and (b) by all other parties in interest, on a CD-ROM, in textsearchable portable document format (PDF) (with a hard copy delivered directly to Chambers), in accordance with the customary practices of the Bankruptcy Court and General Order M-399, to the extent applicable, and served in accordance with General Order M-399 and the Order Pursuant to 11 U.S.C. 105(a) and Fed. R. Bankr. P. 1015(c) and 9007 Implementing Certain Notice and Case Management Procedures, dated April 4, 2017 [ECF No. 101], so as to be filed and received no later than March 20, 2018 at 4:00 p.m. (Eastern Time). If you file a written Response to the Objection, you should plan to appear at the Hearing. The Debtors, however, reserve the right to continue the hearing on the Objection with respect to claim(s) for which a Response has been received. If the Debtors do continue the hearing with respect to such claim(s), then the hearing will be held at a later date. If the Debtors do not continue the hearing with respect to such claim(s), then a hearing on the Objection will be conducted on the above date. WEIL:\ \1\

3 Pg 3 of 37 If no Responses are timely filed and served with respect to the Objection, the Debtors may, on or after the Response Deadline, submit to the Bankruptcy Court an order substantially in the form of the proposed order annexed to the Objection, which order may be entered with no further notice or opportunity to be heard. Dated: February 20, 2018 New York, New York /s/ Robert J. Lemons Gary T. Holtzer Robert J. Lemons Garrett A. Fail David N. Griffiths WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, New York Telephone: (212) Facsimile: (212) Attorneys for Debtors and Debtors in Possession WEIL:\ \1\

4 Pg 4 of 37 HEARING DATE AND TIME: March 27, 2018 at 11:00 a.m. (Eastern Time) RESPONSE DEADLINE: March 20, 2018 at 4:00 p.m. (Eastern Time) THIS OMNIBUS OBJECTION TO CLAIMS SEEKS TO RECLASSIFY CERTAIN FILED PROOFS OF CLAIM. PLEASE CAREFULLY REVIEW THIS OBJECTION AND THE ATTACHMENTS HERETO TO DETERMINE WHETHER THE OBJECTION AFFECTS ANY CLAIM(S) YOU MAY HAVE FILED. IF YOU HAVE QUESTIONS, PLEASE CONTACT DEBTORS COUNSEL, OLGA F. PESHKO, AT WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, New York Telephone: (212) Facsimile: (212) Gary T. Holtzer Robert J. Lemons Garrett A. Fail David N. Griffiths Attorneys for Debtors and Debtors in Possession UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK x In re : Chapter 11 : WESTINGHOUSE ELECTRIC COMPANY : Case No (MEW), et al., : : : Debtors. 1 : (Jointly Administered) : x DEBTORS SEVENTH OMNIBUS OBJECTION TO CLAIMS ( ) 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, if any, are: Westinghouse (0933), CE Nuclear Power International, (8833), Fauske and Associates (8538), Field Services, (2550), Nuclear Technology Solutions (1921), PaR Nuclear Holding Co., (7944), PaR Nuclear, (6586), PCI Energy Services (9100), Shaw Global Services, (0436), Shaw Nuclear Services, (6250), Stone & Webster Asia (1348), Stone & Webster Construction (1673), Stone & Webster International (1586), Stone & Webster Services (5448), Toshiba Nuclear Energy Holdings (UK) Limited (N/A), TSB Nuclear Energy Services (2348), WEC Carolina Energy Solutions, (8735), WEC Carolina Energy Solutions, (2002), WEC Engineering Services (6759), WEC Equipment & Machining Solutions, (3135), WEC Specialty (N/A), WEC Welding and Machining, (8771), WECTEC Contractors (4168), WECTEC Global (8572), WECTEC (6222), WECTEC Staffing Services (4135), Westinghouse Energy Systems (0328), Westinghouse Industry Products International Company (3909), Westinghouse International Technology (N/A), and Westinghouse Technology Licensing Company (5961). The Debtors principal offices are located at 1000 Westinghouse Drive, Cranberry Township, Pennsylvania WEIL:\ \1\

5 Pg 5 of 37 TO THE HONORABLE MICHAEL E. WILES, UNITED STATES BANKRUPTCY JUDGE: Westinghouse ( WEC ) and certain of its affiliates, as debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the Debtors ), respectfully represent: Background 1. On March 29, 2017 (the Petition Date ), each Debtor commenced with this Court a voluntary case under chapter 11 of title 11 of the United States Code (the Bankruptcy Code ). The Debtors are authorized to continue to operate their businesses and manage their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in these chapter 11 cases. 2. The Debtors chapter 11 cases are being jointly administered for procedural purposes only pursuant to Rule 1015(b) of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ). 3. On June 28, 2017, the Court entered an order (the Bar Date Order ) establishing September 1, 2017 at 5:00 p.m. (Eastern Time) as the deadline (the Bar Date ) by which proofs of claim (each a Proof of Claim ), other than those filed by a governmental unit, were required to be filed to assert claims (each a Claim ) in these chapter 11 cases [Docket No. 788]. Pursuant to the Bar Date Order, governmental units were required to assert their claims so that they were actually received on or before September 25, 2017 at 5:00 p.m. (Eastern Time). 4. On December 15, 2017, the Court entered an order (the Settlement Procedures Order ) authorizing the Debtors to file omnibus claims objections and to establish procedures for settling certain claims [Docket No. 1761]. WEIL:\ \1\

6 Pg 6 of Additional information regarding the Debtors business, capital structure, and the circumstances leading to the commencement of these chapter 11 cases is set forth in the Declaration of Lisa J. Donahue Pursuant to Rule of the Local Bankruptcy Rules for the Southern District of New York, sworn to and filed on the Petition Date [Docket No. 4]. Jurisdiction 6. This Court has jurisdiction to consider this matter pursuant to 28 U.S.C. 157 and This is a core proceeding pursuant to 28 U.S.C. 157(b). Venue is proper before this Court pursuant to 28 U.S.C and Relief Requested 7. The Debtors file this omnibus objection to claims, pursuant to section 502(b) of the Bankruptcy Code and Bankruptcy Rule 3007(d), seeking entry of an order, substantially in the form annexed hereto as Exhibit A (the Proposed Order ), reclassifying certain claims listed on Exhibit 1 to the Proposed Order as further described herein. 8. Upon a review of the claims register, the Debtors have concluded that the proofs of claim identified on Exhibit 1 and listed under the heading to be Reclassified (collectively, the ) are claims that are not entitled to secured status, because (1) they are not secured by a lien on property in which the Debtors bankruptcy estates have an interest, or (2) the respective claimant failed to provide evidence of a lien on property in which the Debtors bankruptcy estates have an interest, and the Debtors believe a valid lien on the Debtors property cannot be shown by such claimant. 9. To ensure that the claims register is accurate, the Debtors seek entry of the Proposed Order reclassifying the as general unsecured claims. WEIL:\ \1\

7 Pg 7 of The Debtors also reserve their rights to later object to any Claim on any other basis and object to any claim as to which the Court does not grant the relief requested herein on any other basis. The Relief Requested Should Be Approved by the Court 11. A filed proof of claim is deemed allowed, unless a party in interest... objects. 11 U.S.C. 502(a). Upon an objection, the claimant has the burden to demonstrate the validity of the claim. See Residential Capital,, 2016 WL , at *9 (S.D.N.Y. 2016); In re Arcapita Bank B.S.C.(c), 2013 WL , at *1 (Bankr. S.D.N.Y. 2013), aff'd sub nom. In re Arcapita Bank B.S.C.(c), 508 B.R. 814 (S.D.N.Y. 2014); In re Motors Liquidation Co., 2012 WL , at *3 (S.D.N.Y. 2012); In re Oneida, Ltd., 400 B.R. 384, 389 (Bankr. S.D.N.Y. 2009), aff d, No. 09 Civ (DC), 2010 WL , at *5 (S.D.N.Y. Jan. 22, 2010). 12. Section 502(b)(1) of the Bankruptcy Code provides, in relevant part, that a claim may not be allowed to the extent that such claim is unenforceable against the debtor and property of the debtor, under any agreement or applicable law. 11 U.S.C. 502(b)(1). 13. Section 506(a) of the Bankruptcy Code defines a secured claim, in relevant part, as an allowed claim of a creditor secured by a lien on property in which the estate has an interest, or that is subject to setoff under section to the extent of the value of such creditor s interest in the estate s interest in such property U.S.C. 506(a). 14. that are incorrectly filed by a creditor as secured claims are routinely reclassified as general unsecured claims. See, e.g., In re Dreier LLP, 544 B.R. 760 (Bankr. S.D.N.Y. 2016); In re Residential Capital,, No (MG), 2016 Bankr. LEXIS 635, at *1 (Bankr. S.D.N.Y. Mar. 2, 2016) (noting that a claim was reclassified as a general unsecured claim pursuant to an order granting an omnibus objection to claims); In re WEIL:\ \1\

8 Pg 8 of 37 Residential Capital,, No (MG), 2015 Bankr. LEXIS 97, at *2 (Bankr. S.D.N.Y. Jan. 13, 2015) (noting that a claim was previously reclassified as a general unsecured claim). Pursuant to the Settlement Procedures Order, the Debtors are permitted to file objections to more than one claim on the basis that, among other things, such claims were incorrectly classified. 15. The Debtors have determined that each Claim improperly asserts that it is a secured claim as indicated in the Note below each Claim listed on Exhibit 1. The are not secured by a lien on property in which the estate has an interest and are not subject to setoff under section 553 of the Bankruptcy Code. 16. Accordingly, the Debtors seek entry of an order reclassifying the secured status of each Claim as indicated on Exhibit 1. Reservation of Rights 17. The Debtors hereby reserve the right to object in the future to any of the proofs of claim listed in this objection on any ground, and to amend, modify, and/or supplement this objection to the extent an objection to a claim is not granted. The Objection does not constitute any admission or finding with respect to the amount or validity of the. 18. Notwithstanding anything contained in this Objection or the attached exhibits, nothing herein shall be construed as a waiver of any rights that the Debtors may have to (a) bring avoidance actions under the applicable sections of the Bankruptcy Code against holders of claims subject to the Objection or (b) exercise their right of setoff against the holders of such claims related to such avoidance actions. WEIL:\ \1\

9 Pg 9 of 37 Notice 19. Notice of this Objection has been provided in accordance with Bankruptcy Rule 3007 and the Order Pursuant to 11 U.S.C. 105(a) and Fed. R. Bankr. P. 1015(c) and 9007 Implementing Certain Notice and Case Management Procedures, dated April 4, 2017 [ECF No. 101]. The Debtors submit that, in view of the facts and circumstances, such notice is sufficient and no other or further notice need be provided. 20. No previous request for the relief sought herein has been made by the Debtors to this or any other Court. WEIL:\ \1\

10 Pg 10 of 37 WHEREFORE the Debtors respectfully request entry of an order granting the relief requested herein and such other and further relief as is just. Dated: February 20, 2018 New York, New York /s/ Robert J. Lemons Gary T. Holtzer Robert J. Lemons Garrett A. Fail David N. Griffiths WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, New York Telephone: (212) Facsimile: (212) Attorneys for Debtors and Debtors in Possession WEIL:\ \1\

11 Pg 11 of 37 Exhibit A Proposed Order WEIL:\ \1\

12 Pg 12 of 37 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK x In re : Chapter 11 : WESTINGHOUSE ELECTRIC COMPANY : Case No (MEW), et al., : : : Debtors. 1 : (Jointly Administered) : x ORDER GRANTING DEBTORS SEVENTH OMNIBUS OBJECTION TO CLAIMS ( ) Upon the Seventh Omnibus Objection to ( ) filed on February 20, 2018 (ECF No. [ ]) (the Objection ) by Westinghouse Electric Company and certain of its affiliates, as debtors and debtors in possession in the abovecaptioned chapter 11 cases (collectively, the Debtors ), pursuant to section 502(b) of title 11 of the United States Code (the Bankruptcy Code ); and the Court having jurisdiction to consider the Objection and the relief requested therein in accordance with 28 U.S.C. 157 and 1334 and the Amended Standing Order of M-431, dated January 31, 2012 (Preska, C.J.); and consideration of the Objection and the relief requested therein being a core proceeding pursuant 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, if any, are: Westinghouse (0933), CE Nuclear Power International, (8833), Fauske and Associates (8538), Field Services, (2550), Nuclear Technology Solutions (1921), PaR Nuclear Holding Co., (7944), PaR Nuclear, (6586), PCI Energy Services (9100), Shaw Global Services, (0436), Shaw Nuclear Services, (6250), Stone & Webster Asia (1348), Stone & Webster Construction (1673), Stone & Webster International (1586), Stone & Webster Services (5448), Toshiba Nuclear Energy Holdings (UK) Limited (N/A), TSB Nuclear Energy Services (2348), WEC Carolina Energy Solutions, (8735), WEC Carolina Energy Solutions, (2002), WEC Engineering Services (6759), WEC Equipment & Machining Solutions, (3135), WEC Specialty (N/A), WEC Welding and Machining, (8771), WECTEC Contractors (4168), WECTEC Global (8572), WECTEC (6222), WECTEC Staffing Services (4135), Westinghouse Energy Systems (0328), Westinghouse Industry Products International Company (3909), Westinghouse International Technology (N/A), and Westinghouse Technology Licensing Company (5961). The Debtors principal offices are located at 1000 Westinghouse Drive, Cranberry Township, Pennsylvania WEIL:\ \1\

13 Pg 13 of 37 to 28 U.S.C. 157(b); and venue being proper before this Court pursuant to 28 U.S.C and 1409; and due and proper notice of the Objection having been provided in accordance with Bankruptcy Rule 3007 and the Order Pursuant to 11 U.S.C. 105(a) and Fed. R. Bankr. P. 1015(c) and 9007 Implementing Certain Notice and Case Management Procedures; and a hearing having been held on March 27, 2018 at 11 a.m. (Eastern Time) to consider the relief requested in the Objection (the Hearing ); and Debtors counsel having certified that no responses to the claims to be reclassified pursuant to this order were filed or received; and the Court having found and determined that the relief sought in the Objection is in the best interests of the Debtors, their estates, creditors, and all parties in interest, and that the legal and factual bases set forth in the Objection establish just cause for the relief granted herein; and after due deliberation and sufficient cause appearing therefor, it is ORDERED that the relief requested in the Objection is granted to the extent set forth herein; and it is further ORDERED that, pursuant to section 502(b) of the Bankruptcy Code and Bankruptcy Rule 3007, each of the claims listed under the heading to be Reclassified on Exhibit 1 annexed hereto (collectively, the ) is hereby reclassified as a general unsecured claim as indicated on Exhibit 1 ; and it is further ORDERED that nothing herein shall constitute an admission or finding concerning the amount or validity of any of the ; and it is further ORDERED that this Order has no res judicata, estoppel, or other effect on the validity, allowance, or disallowance of, and all rights to object to or defend on any basis are expressly reserved with respect to, any Claim referenced and/or identified in the Objection that is not listed on Exhibit 1 annexed hereto; and it is further WEIL:\ \1\

14 Pg 14 of 37 ORDERED that the Debtors, the Debtors claims and noticing agent, Kurtzman Carson Consultants, and the Clerk of this Court are authorized to take all actions necessary or appropriate to give effect to this Order; and it is further ORDERED that this Court shall retain jurisdiction over the Debtors and the claimants whose claims are subject to the Objection with respect to any matters related to or arising from the Objection or the implementation of this Order. Dated:, 2018 New York, New York HONORABLE MICHAEL E. WILES UNITED STATES BANKRUPTCY JUDGE WEIL:\ \1\

15 Pg 15 of 37 WEIL:\ \1\

16 Pg 16 of 37 ABB Robinson and Cole LLP 280 Trumbull Street Hartford, CT WECTEC Global $2,665, $1,878, $4,543, $4,543, $4,543, Aecon Industrial, A Division Of Aecon Construction Group, 150 Sheldon Drive Cambridge, ON N1R7K WECTEC Global $7,443, $7,589, $1,470, $15,033, $1,470, Amec Foster Wheeler Enviornment Infrastructure 1105 Lakewood Parkway Suite 300 Alpharetta, GA Westinghouse $556, $556, $556, $556, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 1

17 Pg 17 of 37 Amec Foster Wheeler Environment Infrastructure, 1105 Lakewood Parkway, Suite 300 Alpharetta, GA Westinghouse $2,607, $2,607, $2,607, $2,607, Blanchard Machinery 3151 Charleston Highway Columbia, SC WECTEC Global $535, $28, $28, $535, $563, $563, Blythewood Oil Company Inc PO Box 123 Blythewood, SC Westinghouse $86, $154, $154, $86, $241, $241, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 2

18 Pg 18 of 37 Bulldog Erectors, 245 Industrial Park Road Newberry, SC WECTEC Global $11,810, $3,028, $14,838, $14,838, $14,838, Claim Transfered To: Whitebox Multi-Strategy Partners, LP Attn Scott Specken 3033 Excelsior Blvd., Ste. 300 Minneapolis, MN Whitebox Asymmetric Partners, LP Attn Scott Specken 3033 Excelsior Blvd., Ste. 300 Minneapolis, MN Whitebox Caja Blanca Fund, LP Attn Scott Specken 3033 Excelsior Blvd., Ste. 300 Minneapolis, MN C.A. Murren and Sons Company, 2275 Loganville Hwy. Grayson, GA WECTEC Contractors $952, $952, $952, $952, C.A. Murren and Sons Company, 2275 Loganville Hwy. Grayson, GA WECTEC Contractors $757, $757, $757, $757, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 3

19 Pg 19 of 37 CANNON SLINE INDUSTRIAL, INC. C/O HINCKLEY, ALLEN & SNYDER LLP 28 STATE STREET BOSTON, MA WECTEC Contractors $4,599, $4,599, $4,599, $4,599, Claim Transfered To: Whitebox Asymmetric Partners, LP Attn Scott Specken 3033 Excelsior Blvd., Ste. 300 Minneapolis, MN Whitebox Asymmetric Partners, LP Attn Scott Specken 3033 Excelsior Blvd., Ste. 300 Minneapolis, MN Commercial Siding and Maintenance Company 300 Galleria Parkway, SE Suite 1000 Atlanta, GA WECTEC Global $513, $513, $513, $513, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 4

20 Pg 20 of 37 Eaton Corporation 1000 Eaton Blvd., N3 Cleveland, OH WECTEC Global $2,248, $1,761, $4,009, $4,009, $4,009, Eaton Corporation 1000 Eaton Blvd., N3 Cleveland, OH Westinghouse $27, $27, $27, $27, Ed Waters and Sons Contracting Co., Kenison, Dudley Crawford, Law Firm 704 East McBee Avenue Columbia, SC Westinghouse $2,466, $2,466, $2,466, $2,466, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 5

21 Pg 21 of 37 Fergon Tool & Machine Co Inc 200 Fergon Road Lexington, SC Westinghouse $21, $21, Claim Transfered To: Cherokee Debt Acquistion, Attn Vladimir Jelisavic 1325 Avenue of the Americas, 28th Floor New York, NY $21, $21, Greenberry Industrial, Perkins Coie, LLP 1201 Third Avenue, Ste Seattle, WA Westinghouse $3,818, $3,818, $3,818, $3,818, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 6

22 Pg 22 of 37 Gregory, 2124 College Street Columbia, SC WECTEC Contractors $16, $16, $16, $16, Gregory, 2124 College Street Columbia, SC WECTEC Contractors $70, $70, $70, $70, Gregory, 2124 College Street Columbia, SC WECTEC Contractors $149, $12, $12, $149, $161, $161, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 7

23 Pg 23 of 37 Gregory, 2124 College Street Columbia, SC WECTEC Contractors $33, $33, $33, $33, HD Supply Construction Supply, Ltd. d/b/a HD Supply Construction & Industrial - White Cap 301 South College Street, Suite 2900 Charlotte, NC WECTEC Global $90, $90, $90, $90, HD Supply Construction Supply, Ltd. d/b/a HD Supply Construction & Industrial - White Cap 301 South College Street, Suite 2900 Charlotte, NC WECTEC Global $266, $266, $266, $266, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 8

24 Pg 24 of 37 HD Supply Construction Supply, Ltd. d/b/a HD Supply Construction & Industrial - White Cap 301 South College St., Suite 2900 Charlotte, NC WECTEC Global $20, $20, $20, $20, Herc Rentals 2900 K Street NW, North Tower- Suite 200 Washington, DC Stone & Webster Construction $3,295, $41, $3,336, $3,336, $3,336, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 9

25 Pg 25 of 37 Intertech Security, Tucker Arensberg, P.C One PPG Place Pittsburgh, PA WECTEC Contractors $291, $291, $291, $291, Intertech Security, Tucker Arensberg, P.C One PPG Place Pittsburgh, PA Stone & Webster Construction $183, $183, $183, $183, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 10

26 Pg 26 of 37 Leidos Engineering Freedom Drive Reston, VA WECTEC Global $5,931, $747, $5,685, $6,679, $5,685, Leidos Engineering Freedom Drive Reston, VA WECTEC Global $5,931, $3,625, $9,556, $9,556, $9,556, Lisega 370 E Dumplin Valley Rd Kodak, TN Westinghouse $222, $22, $73, $245, $73, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 11

27 Pg 27 of 37 LISEGA INC - USA 370 E DUMPLIN VALLEY RD KODAK, TN Westinghouse $109, $4, $4, $109, $114, $114, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 12

28 Pg 28 of 37 Martin Marietta Materials, Nexsen Pruet, P 4141 Parklake Avenue, Suite 200 Raleigh, NC WECTEC Global $1,422, $545, $545, $1,422, $1,968, $1,968, Martin Marietta Materials, 4141 Parklake Avenue, Suite 200 Raleigh, NC WECTEC Global $61, $61, $61, $61, Martin Marietta Materials, 4141 Parklake Avenue, Suite 200 Raleigh, NC WECTEC Contractors $221, $48, $48, $221, $270, $270, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 13

29 Pg 29 of 37 Measurement Computing Corp. 10 Commerce Way, Suite 10F Norton, MA Westinghouse $1, $1, $1, $1, MURPHY RIGGING + ERECTING INC TH AVE SE MINNEAPOLIS, MN Westinghouse $171, $171, $171, $171, MURPHY WAREHOUSE COMPANY TH AVENUE SE MINNEAPOLIS, MN Westinghouse $33, $33, $33, $33, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 14

30 Pg 30 of 37 Myers & Chapman, 1101 Woodridge Center Dr. Ste 160 Charlotte, NC Westinghouse $19, $19, $19, $19, Oldcastle Precast, Oldcastle Law Group 900 Ashwood Parkway, Suite 600 Atlanta, GA WECTEC Global $151, $72, $224, $224, $224, Pipe Valve and Fitting Co. PO Box 5806 Denver, CO Westinghouse $1, $1, $1, $1, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 15

31 Pg 31 of 37 Ram Tool and Supply Co., th Avenue South Birmingham, AL WECTEC Global $291, $291, $291, $291, S&ME, 3201 Spring Forest Road Raleigh, NC Westinghouse $138, $138, $138, $138, S&ME, 3201 Spring Forest Road Raleigh, NC Westinghouse $467, $467, $467, $467, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 16

32 Pg 32 of 37 Shealy Electrical Wholesalers, 704 East McBee Avenue Greenville, SC Westinghouse $133, $133, $133, $133, SHELBY MECHANICAL INC 1009 BROAD STREET CINNAMINSON, NJ WECTEC Contractors $601, $601, Claim Transfered To: Whitebox Asymmetric Partners, LP Attn Scott Specken 3033 Excelsior Blvd., Ste. 300 Minneapolis, MN Whitebox Multi-Strategy, LP Attn Scott Specken 3033 Excelsior Blvd., Ste. 300 Minneapolis, MN $601, $601, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 17

33 Pg 33 of 37 SteelFab, 5 Concourse Parkway, Ste Atlanta, GA WECTEC Global $91, $10, $10, $91, $102, $102, SteelFab, 5 Concourse Parkway, Ste Atlanta, GA WECTEC Global $848, $1,475, $2,323, $2,323, $2,323, SteelFab, 5 Concourse Parkway, Ste 2600 Atlanta, GA WECTEC Global $669, $62, $62, $669, $731, $731, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 18

34 Pg 34 of 37 SteelFab, 5 Concourse Parkway, Suite 2600 Atlanta, GA WECTEC Global $212, $197, $410, $410, $410, STONHARD DIV OF STONCOR GROUP 1000 E PARK AVE MAPLE SHADE, NJ Westinghouse $9, $9, $9, $9, Superheat FGH Services 1401 Enclave Parkway, Suite 125 Houston, TX Westinghouse $1,291, $1,291, $1,291, $1,291, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 19

35 Pg 35 of 37 The Calvert Company, Akerman LLP 666 Fifth Avenue, 20th Floor New York, NY WECTEC Global $6,569, $3,800, $6,569, $3,800, The Calvert Company, Akerman LLP 666 Fifth Avenue, 20th Floor New York, NY Stone & Webster Construction $308, $139, $30, $478, $478, $478, The Lincoln St Clair Ave Cleveland, OH WECTEC Global $265, $265, $265, $265, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 20

36 Pg 36 of 37 Thompson Industrial Services, 104 North Main Street Sumter, SC WECTEC Global $147, $147, $147, $147, Thompson Industrial Services, 104 North Main Street Sumter, SC WECTEC Contractors $1,298, $1.00 $1,298, $1,298, $1,298, Thompson Services PO Box Columbia, SC Westinghouse $331, $99, $99, $331, $430, $430, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 21

37 Pg 37 of 37 Tindall Corporation 300 Galleria Parkway, SE Suite 1000 Atlanta, GA WECTEC Global $370, $118, $118, $370, $488, $488, (2) on the exhibit are sorted in alphabetical order based on the creditor name as listed on proof of claim form. Page 22