mew Doc 267 Filed 04/18/17 Entered 04/18/17 17:17:41 Main Document Pg 1 of 3

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1 mew Doc 267 Filed 04/18/17 Entered 04/18/17 17:17:41 Main Document Pg 1 of 3 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK : In re: : Case No.: MEW : (Jointly Administered) WESTINGHOUSE ELECTRIC, : COMPANY LLC, et al., : (Chapter 11) : Debtors. : : : NOTICE OF RECLAMATION DEMAND OF CURTISS-WRIGHT ELECTRO-MECHANICAL CORPORATION PLEASE TAKE NOTICE that, by and through its undersigned counsel, Curtiss-Wright Electro-Mechanical Corporation ( EMD ) hereby files this notice of delivery of a written demand, pursuant to 503 and 546 of title 11 of the United States Code, and applicable nonbankruptcy law on the above-captioned debtors and debtors-in-possession (the Debtors ) to reclaim certain assets (the Goods ) that are subject to reclamation. The Goods were sold in the ordinary course of EMD s business and delivered on credit terms to, and received by, the Debtors during the 45 days prior to the filing of the Debtors bankruptcy petitions. EMD believes that the Debtors were insolvent at the time they received delivery of the Goods. EMD attaches as Exhibit A and incorporates by reference herein, a copy of its formal reclamation demand letter delivered to the Debtors on April 11, EMD hereby reserves all other rights and interests with respect to the Goods.

2 mew Doc 267 Filed 04/18/17 Entered 04/18/17 17:17:41 Main Document Pg 2 of 3 Date: April 18, 2017 /s/ Brent C. Strickland Brent C. Strickland (BS 7811) Whiteford Taylor Preston L.L.P Wisconsin Avenue, Suite 700w Bethesda, Maryland Telephone: (410) bstrickland@wtplaw.com -and- Stephen B. Gerald Whiteford, Taylor & Preston LLC The Renaissance Centre 405 North King Street, Suite 500 Wilmington, Delaware Telephone: (302) sgerald@wtplaw.com Attorneys for Curtiss Wright Electro- Mechanical Corporation, et al. 2

3 mew Doc 267 Filed 04/18/17 Entered 04/18/17 17:17:41 Main Document Pg 3 of 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 17 th day of April, 2017, copies of the foregoing Notice of Reclamation Demand were sent to all parties requesting service via ECF notification and by first class mail, postage prepaid, to: Gary T. Holzer Robert J. Lemons Garrett A. Fail WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, NY United States Trustee U.S. Federal Office Building 201 Varick Street, Room 1006 New York, NY Albert Togut Togut, Segal & Segal LLP One Penn Plaza, Suite 3335 New York, NY /s/ Brent C. Strickland Brent C. Strickland 3

4 Pg 1 of 8 EXHIBIT A

5 Pg 2 of 8 Curtiss-Wright Corporation 1000 Wright Way Cheswick, PA T: curtisswright.com April 11, 2017 BY TO dudiakjg@westinghouse.com AND BY FEDERAL EXPRESS BY FEDERAL EXPRESS Mr. Jan Dudiak Mr. Gary T. Holtzer Vice President and Chief Procurement Officer Mr. Robert J. Lemons Westinghouse Electric Company, LLC Mr. Garrett A. Fail Cranberry Woods Headquarters Weil, Gotshal & Manges LLP 1000 Westinghouse Drive 767 Fifth Avenue Cranberry Township, PA New York, New York Attorneys for Debtors and Debtors in Possession BY TO sweenemt@westinghouse.com AND BY FEDERAL EXPRESS Mr. Michael T. Sweeney Senior Vice President and General Counsel Westinghouse Electric Company, LLC Cranberry Woods Headquarters 1000 Westinghouse Drive Cranberry Township, PA RE: Reclamation Demand by Curtiss-Wright Electro-Mechanical Corporation to Westinghouse Electric Company, LLC To the Above Addressed Recipients: I represent Curtiss-Wright Electro-Mechanical Corporation ( EMD ). In compliance with Section 546 of the Bankruptcy Code and other applicable law, this letter constitutes EMD s reclamation demand upon Westinghouse Electric Company, LLC and its affiliated debtors and debtors-in-possession (the Debtors ) for all goods that the Debtors received from EMD within 45 days immediately preceding March 29, 2017, as identified herein. EMD is revoking the delivery of these goods and pursuing reclamation thereof because the goods have not been paid for in full. EMD s reclamation demand covers, without limitation, all goods represented by the invoices listed on the enclosed spreadsheets, which total $1,326,075. The goods are identified on invoices 28876, and 28986, which are being sent along with the original of this letter. The subject goods were sold by EMD to the Debtors in the ordinary course of EMD s business, are identifiable, and were received and accepted by the Debtors while insolvent. Further, this demand is made within the applicable time periods of the Bankruptcy Code. Accordingly, EMD demands reclamation of the subject goods, that such goods be segregated and that the Debtors make immediate arrangements for EMD to take possession of these goods. Please contact us as soon as possible to make arrangements for EMD to repossess such goods. Further, EMD demands an accounting and inventory from the Debtors of all the goods subject to reclamation by EMD and that the Debtors not sell, use or integrate the subject goods. EMD reserves all rights and remedies under any instrument, agreement or applicable law including but not limited to the right to further amend or supplement its reclamation demand or to make

6 Pg 3 of 8 Westinghouse Electric Company, LLC April 11, 2017 Page 2 additional demands or claims at law or in equity. If you have any questions or require any further information, please let me know. I appreciate your immediate attention to this matter. Sincerely, David P. Maivald Associate General Counsel Chief Intellectual Property Counsel Curtiss-Wright Corporation Enclosures

7 Pg 4 of 8 Westinghouse PO Number Invoice Amount Invoice Number Invoice Date Milestone Delivery Date $ 1,142, Feb-17 U600 MILESTONE #24A SHIPMENT OF RCP -VSG UNIT 2-2 RCPs PO Line Item 1 2/23/ $ 129, Feb-17 U600 MILESTONE #24A ESCALATION FOR SHIPMENT OF RCP VSG UNIT 2-2 RCPs PO Line Item 3 2/23/2017

8 Pg 5 of 8 Project (PO) Invoice # AR Invoice Date Due Day-Mo-Yr Description Total XX /15/ Apr-17 See Below $54, SUM $54, XX01 Sales Order Purchase Order Line Item Part Number Description Qty Amount Shipment Date B73E76 O-RING INSPECTED 21 $ 12, Mar B875G01 SPECIAL SHIMS 3 $ 14, Mar EXP CHRG EXPEDITING CHARGE 1 $ 1, Mar C08H20 ROD SCRAPER-SHOCK ABS. 10 $ Mar B492E79 O-RING INSPECTED 8 $ 3, Mar B486H05 CHANNEL SEAL-DOUBLE DELTA 3 $ 1, Mar DOC CHRG DOCUMENTATION CHARGE 1 $ Mar B486H07 CHAN SEAL 4 $ 4, Mar DOC CHRG DOCUMENTATION CHARGE 1 $ Mar B493E81 O-RING INSPECTED 9 $ 4, Mar B493T78 O-RING INSPECTED 10 $ 3, Mar DOC CHRG DOCUMENTATION CHARGE 1 $ Mar B486H05 CHANNEL SEAL-DOUBLE DELTA 2 $ 1, Mar DOC CHRG DOCUMENTATION CHARGE 1 $ Mar B493T78 DOCUMENTATION CHARGE 4 $ 1, Mar D DOC CHRG DOCUMENTATION CHARGE 1 $ Mar B492E79 DOCUMENTATION CHARGE 4 $ 1, Mar D DOC CHRG DOCUMENTATION CHARGE 1 $ Mar-17 SUM $ 54,105.00

9 Pg 6 of 8 ELECTRO-MECHANICAL CORPORATION REMIT TO: CURTISS-WRIGHT ELECTRO-MECHANICAL CORP. P.O. BOX PITTSBURGH, PA CHARGE TO: INVOICE NO. CUST NO. INVOICE DATE INVOICE FEB-17 SHIP TO: PO NUMBER SHIPMENT NO. DATE SHIPPED SHIPPED VIA TERMS NET ITEM STYLE NO. & DESCRIPTION UNIT PRICE QTY AMOUNT 1 U600 MILESTONE #24A SHIPMENT OF RCP -VSG UNIT 2-2 RCPs P.O. LINE ITEM 1 1,142, ,142, SPECIAL INSTRUCTIONS: SUBTOTAL 1,142, SALES TAX 0.00 FREIGHT 0.00 TOTAL 1,142, We hereby certify that these goods were produced in compliance with all applicable requirements of Sections 6, 7, and 12 of the Fair Labor Standards Act, as amended, and of regulations and orders of the United States Department of Labor, issued under Section 14 thereof. NOTICE: Price hereon, following our company policy, may be based upon price(s) in effect at time of shipment, therefore may not be the same as the price(s) on your order.

10 Pg 7 of 8 ELECTRO-MECHANICAL CORPORATION REMIT TO: CURTISS-WRIGHT ELECTRO-MECHANICAL CORP. P.O. BOX PITTSBURGH, PA CHARGE TO: INVOICE NO. CUST NO. INVOICE DATE INVOICE FEB-17 SHIP TO: PO NUMBER SHIPMENT NO. DATE SHIPPED SHIPPED VIA TERMS NET ITEM STYLE NO. & DESCRIPTION UNIT PRICE QTY AMOUNT 1 U600 MILESTONE #24A ESCALATION FOR SHIPMENT OF RCP VSG UNIT 2-2 RCPs P.O. LINE ITEM 3 129, , SPECIAL INSTRUCTIONS: SUBTOTAL 129, NOTE: PNC BANK ACCT # ABA SALES TAX 0.00 FREIGHT 0.00 TOTAL 129, We hereby certify that these goods were produced in compliance with all applicable requirements of Sections 6, 7, and 12 of the Fair Labor Standards Act, as amended, and of regulations and orders of the United States Department of Labor, issued under Section 14 thereof. NOTICE: Price hereon, following our company policy, may be based upon price(s) in effect at time of shipment, therefore may not be the same as the price(s) on your order.

11 Pg 8 of 8 ELECTRO-MECHANICAL CORPORATION REMIT TO: CURTISS-WRIGHT ELECTRO-MECHANICAL CORP. P.O. BOX PITTSBURGH, PA CHARGE TO: INVOICE NO. CUST NO. INVOICE DATE INVOICE MAR-17 SHIP TO: PO NUMBER SHIPMENT NO. DATE SHIPPED SHIPPED VIA TERMS 2017 XX01 SPARES ORDERS 30 NET ITEM STYLE NO. & DESCRIPTION UNIT PRICE QTY AMOUNT 1 XX01 SPARE PART SHIPMENTS FOR THE MONTH OF MAR 54, , SPECIAL INSTRUCTIONS: SUBTOTAL 54, SALES TAX 0.00 FREIGHT 0.00 TOTAL 54, We hereby certify that these goods were produced in compliance with all applicable requirements of Sections 6, 7, and 12 of the Fair Labor Standards Act, as amended, and of regulations and orders of the United States Department of Labor, issued under Section 14 thereof. NOTICE: Price hereon, following our company policy, may be based upon price(s) in effect at time of shipment, therefore may not be the same as the price(s) on your order.