Case BLS Doc 137 Filed 01/21/13 Page 1 of 4 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

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1 Case BLS Doc 137 Filed 01/21/13 Page 1 of 4 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 REVSTONE INDUSTRIES, LLC, Case No (BLS) Debtor. I Related Docket No. 126 DEBTOR S RESPONSE TO MOTION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR AN EXPEDITED HEARING FOR COMMITTEE S 2004 MOTION REGARDING ANY PROPOSED SALE OF METAVATION, LLC AND/OR CONTECH CASTINGS, LLC The Debtor and Debtor in Possession (the "Debtor") in the above-captioned case hereby presents its response to the Committee s Motion to Shorten 2 seeking an expedited hearing on its Rule 2004 Motion regarding any proposed sale of non-debtor subsidiaries Metavation, LLC and Contech Castings, LLC. For the reasons stated below, an expedited hearing on the Rule 2004 Motion is neither necessary nor appropriate at this time. On January 17, 2013, the Debtor filed a notice substituting Pachulski Stang Ziehl & Jones LLP ("PSZJ") as counsel. Recognizing the priority of the Committee s information requests, within an hour of its retention as substitute counsel, PSZJ contacted Committee counsel to discuss, among other topics, the Rule 2004 Motion and the related Motion to Shorten. On calls between counsel on January 17 and January 18, PSZJ expressed its intent to respond to the information requests included in the Rule 2004 Motion, and asked the Committee for a brief breathing spell to allow PSZJ to come up-to-speed in this case. Despite the reasonableness of the request, the The federal tax identification number for the Debtor, Revstone Industries, LLC, is The location of the Debtor s corporate headquarters and the Debtor s address for service of process is 2250 Thunderstick Dr., Ste. 1203, Lexington, Kentucky Capitalized terms not defined herein shall have the same meaning as defined in the Motion to Shorten. DOCSDE:

2 Case BLS Doc 137 Filed 01/21/13 Page 2 of 4 Committee has not agreed to suspend its request for an expedited hearing on the Rule 2004 Motion and the Debtor has been compelled to file this preliminary response. There is no need for an expedited hearing on the Rule 2004 Motion at this time. The Debtor is actively providing information to the Committee regarding the marketing and proposed sale of certain of its assets as well as efforts by certain of its non-debtor subsidiaries to sell certain of their assets (including such efforts with respect to Metavation and Contech Castings). 3 Contrary to the representations of the Committee in the Motion to Shorten, the contemplated sale by non- Debtor Revstone Transportation, LLC of its membership interest in Metavation has neither been a secret nor hidden from the Committee. In particular, the financial advisors of the Debtor and Committee have had multiple conversations in which the proposed transaction and sale process were discussed. Moreover, Mr. Jay Brown, the Debtor s Treasurer, publicly referenced the contemplated transaction during the Revstone 341 meeting on January 9, Further, the Debtor has provided the Committee, through its financial advisor, with a number of documents related to the contemplated Metavation sale including but not limited to: (a) a detailed summary of the contemplated transaction describing a sale process that began in October of last year and has culminated in a contemplated transaction; (b) a sources and uses analysis provided by the proposed purchaser; (c) a summary comparison of the letters of intent received in connection with the sale; (d) certain credit agreement amendments related to the sale; (e) equipment support agreements related to the sale assets; and (f) a support agreement for the sale from General Motors, LLC. 4 The estate s interests in Metavation and Contech Castings are held through its non-debtor subsidiary Revstone Transportation, LLC. See organizational chart attached hereto as Exhibit A. " The Committee recognizes the receipt of the GM support agreement in its Rule 2004 Motion but does not admit that the agreement was provided by the Debtor. DOCS_DE:

3 Case BLS Doc 137 Filed 01/21/13 Page 3 of 4 Also, on Saturday, January 19, the Debtor s financial advisors provided numerous documents (attached to 17 s) to the Committee s financial advisors. The documents provided included financial information regarding Metavation. Thus, while the Debtor recognizes the Committee has additional requests for documents and will further respond the Committee s inquiries related to asset sales, the sale process has not been "secretive" or "concealed" as the Committee dramatically asserts in its motions. This Court does not need to intervene on an expedited basis to facilitate information sharing between the Debtor and Committee. As set forth above, the information flow between the Debtor and the Committee regarding Metavation and other matters is robust. The Debtor reserves its right to respond in greater detail when and if the Committee s 2004 Motion is scheduled for hearing and an objection deadline related to the 2004 Motion is set by this Court or further notice of the Committee. DOCSDE:

4 Case BLS Doc 137 Filed 01/21/13 Page 4 of 4 WHEREFORE, the Debtor respectfully requests that the Court deny the Committee s request for an emergency hearing and direct the Committee to set the Rule 2004 Motion for the next regularly scheduled hearing in this case. Dated: January, 2013 PACHUJ(SKI STZIEHL NG & JONES LLP )r Laura Davis Jones (Bar No. 2436) David M. Bertenthal (CA Bar No ) Timothy P. Cairns (Bar No. 4228) 919 North Market Street, 17 Ih Floor P.O. Box 8705 Wilmington, DE (Courier 19801) Telephone: (302) Facsimile: (302) ljones@pszjlaw.com dbertenthal@pszjlaw.com tcairnspszjlaw.com [Proposed] Counsel to the Debtor and Debtor in Possession DOCSDE:

5 Case BLS Doc Filed 01/21/13 Page 1 of 2 EXHIBIT A Revstone, LLC Organizational Chart DOCSDE:

6 Case BLS Doc Filed 01/21/13 Page 2 of 2 Revstone Industries, LLC Organizational Chart Scott R. Hofmeister Megan G. F-lofmeister Jamie S. Hofmeister Irrevocable Trust Irrevocable Trust Irrevocable Trust Ascalon Enterprises, LLC Revstone Industries, LLC Revstone Mexico Holdings, LLC Revstone I I Revslone Tout &I national sari! Enalneering. LLC,nrboorg Entity)i Canada Inc. L C. nnfntcc Revatone Aarkel Tool mbourg sari! 1 i Die Inc. I *49% Creative Lighting Solutions, LLC I 1% Interest jtr0nes1 s. Interest Magnesiumei 1 99% 1% Interest Revotone MeXICO, Interest Is. De R.L DCCV.! (Mexican Entity) Interest Revotono iers000y Girth (Orirtian Enely) ansing Tool & US 1001& Engineering, Engineering. LLC LLC C Mini Laces Mi,rt,, Creative Lighting Thhnnloginrt 1 LioCCe (Co Rn) UL SoluCnent. tic onta Rican EnlIst 1., (CoCic Rican Entry 1,---, Metavatlon. LLC MW Texas Di Casting, Inc. Castings. LLC I I MetavationI I Metavation I Mexico, LLC I IMexico II, LLC i I 99%( 11% Interest Eptec S.A. I Interest 4 DeC.V. I-- (Mexican Entity)! Traverse-City Metavatiofl MIDS. LLC Builutng Three, Vassar, LLC Real Estate Holdings, LLC (Note: all entities formed in Delaware unless otherwise Indicated.) Page 1 of 1

7 Case BLS Doc Filed 01/21/13 Page 1 of 4 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 REVSTONE INDUSTRIES, LLC, Case No (BLS) Debtor. CERTIFICATE OF SERVICE I, Timothy P. Cairns, hereby certify that on the 21st day of January, 2013, I caused a copy of the following document(s) to be served on the individuals on the attached service list(s), in the manner indicated thereon: DEBTOR S RESPONSE TO MOTION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR AN EXPEDITED HEARING FOR COMMITTEE S 2004 MOTION REGADING ANY PROPOSED SALE OF METAVATION, LLC AND/OR CASTINGS, LLC COr(ECH I -~-S, ) - Timothy P. Cairns (Bar No. 4228) The federal tax identification number for the Debtor, Revstone Industries, LLC, is The location of the Debtor s corporate headquarters and the Debtor s address for service of process is 2250 Thunderstick Dr., Ste. 1203, Lexington, Kentucky DOCS_DE: /001

8 Case BLS Doc Filed 01/21/13 Page 2 of 4 Revstone Industries 2002 Service List Case No (BLS) (Counsel to Schoeller Arca Systems, Inc.) Document No Carl N. Kunz, III, Esquire 07 Morris James LLP Delaware Avenue, Suite 1500 P. 0. Box 2306 Jane Leamy, Esquire Office of the United States Trustee 844 King Street, Suite 2207 Lockbox 35 (Counsel to Ford Motor Company) Karen C. Bifferato, Esquire Connolly Galigaher LLP 1000 West Street, Suite 1400 (Counsel to Airgas, Inc. and related Airgas entities) Kathleen M. Miller, Esquire Smith, Katzenstein & Jenkins LLP The Corporate Plaza 800 Delaware Avenue, Suite 1000 P. 0. Box 410 Wilmington, DE (Counsel to Boston Financial Group) Stuart M. Brown, Esquire R. Criag Martin, Esquire Cynthia Moh, Esquire DLA Piper LLP (US) 919 N. Market Street, 15th Floor (Counsel to United Steelworkers) Susan E. Kaufman, Esquire Cooch and Taylor, P.A West Street, 10th Floor P. 0. Box 1680 (Counsel to Official Committee of Unsecured Creditors) Matthew P. Ward, Esquire Steven K. Kortanek, Esquire Mark L. Degrosseilliers, Esquire Womble Carlyle Sandridge & Rice, LLP 222 Delaware Avenue, Suite 1501 Securities & Exchange Commission Secretary of the Treasury 100 F. Street, NE Washington, DC George S. Canellos, Esquire Securities & Exchange Commission, New York Regional Office 3 World Financial Center, Suite 400 New York, NY Delaware State Treasury 820 Silver Lake Blvd., Suite 100 Dover, DE DOCSDE: /001

9 Case BLS Doc Filed 01/21/13 Page 3 of 4 Secretary of State Division of Corporations - Franchise Tax P.O. Box 898 Dover, DE (Co-counsel to Debtor) Brian Trust, Esquire Howard S. Beltzer, Esquire Frederick D. Hyman, Esquire Mayer Brown LLP 1675 Broadway New York, NY (Counsel to General Motors LLC) Aaron M. Silver, Esquire Honigman Miller Schwartz and Cohn LLP 2290 First National Building 660 Woodward Avenue, Suite 2290 Detroit, MI (Counsel to Chrysler Group LLC) Sheryl L. Toby, Esquire Dykema Gossett PLLC Woodward Ave., Suite 300 Bloomfield Hills, MI (Counsel to JTEKT North America, Inc.) Michael B. Baum, Esquire Daniel J. Weiner, Esquire Jeffery J. Sattler, Esquire Schafer and Weiner, PLLC Woodward Ave., Ste. 100 Bloomfield Hills, MI (Counsel to Ford Motor Company) Stephen S. LaPlante, Esquire Miller Canfield 150 West Jefferson, Suite 2500 Detroit, MI David Boyle Airgas, Inc. 259 Radnor-Chester Road, Suite 100 P. 0. Box 6675 Radnor, PA Desiree M. Amador Pension Benefit Guaranty Corp. Office of the Chief Counsel 1200 K Street, N.W. Washington, DC (Secretary of Labor, U.S. Department of Labor) RubenR. Chapa, Esquire Senior Trial Attorney, Office of the Solicitor U.S. Department of Labor 230 South Dearborn, Room 844 Chicago, IL (Secretary of Labor, U.S. Department of Labor) Matthew M. Scheff, Esquire Trial Attorney - U.S. Department of Labor Office of the Solicitor 1240 E. 9th Street, Room 881 Cleveland, OH (Counsel to Boston Financial Group) Gregg M. Galardi, Esquire Gabriella Zborovsky, Esquire DLA Piper LLP (US) 1251 Avenue of the Americas, 27th Floor New York, NY DOCSDE: /001 2

10 Case BLS Doc Filed 01/21/13 Page 4 of 4 (Counsel to Nexteer Automotove Corporation) Thomas B. Radom, Esquire Butzel Long, a professional corporation Stoneridge West Woodward Avenue Bloomfield Hills, MI (Counsel to Gary Walter, Vigin Hoey and David Bagby) Don Darnell, Esquire Darnell Law Offices 7926 Ann Arbor Street Dexter, MI (Counsel to Native American Logistics Worldwide, LLC) Kevin N. Summers, Esquire Dean & Fulkerson, P.C. 801 W. Big Beaver Road, Suite 500 Troy, MI (Counsel to Multi-Precision Detail, Inc.) Steven A. Siman, Esquire Steven A. Siman, P.C W. Big Beaver, Suite 344 Troy, MI (Counsel to United Steelworkers) David R. Jury, Esquire Associate General Counsel United Steelworkers Five Gateway Center, Room 807 Pittsburgh, PA (Counsel to George S. Hofineister) Sheldon S. Toll, Esquire Sheldon S. Toll PLLC 2000 Town Center, Suite 2100 Southfield, MI DOCSDE: /001