UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA In re Reilly-Benton Co., Inc., Debtor. Case No. 17-12870

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA In re Reilly-Benton Co., Inc., Debtor. Case No. 17-12870 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA In re Reilly-Benton Co., Inc., Debtor. Case No. 17-12870 NOTICE OF MOTION TO APPROVE SETTLEMENT AGREEMENT AND POLICY BUY-BACK AND ENTER INJUNCTION PLEASE TAKE NOTICE THAT David V. Adler, as Chapter 7 trustee (the "Trustee") of the bankruptcy estate (the "Estate") of debtor Reilly-Benton Co., Inc. ("RBC"), has requested the U.S. Bankruptcy Court for the Eastern District of Louisiana (the "Bankruptcy Court") to conduct a hearing on October 15, 2025, at 10:30 a.m. Central Daylight Time on a motion (the "Motion") to approve a Settlement Agreement[1] between (i) the Trustee and (ii) Employers Mutual Fire Insurance Company and Employers Insurance Company of Wausau (collectively, the "Insurers"), resolving disputes regarding certain historical liability insurance policies (the "Policies") issued by the Insurers to RBC, or under which RBC is insured or may claim to be insured or entitled to benefits. Under the terms of the Settlement Agreement, (a) the Insurers agree to pay the settlement amount ($1.4 million) to the Trustee on behalf of the Estate (as defined in the Settlement Agreement), (b) the Insurers and their Affiliates will receive a release of all past, present, and future Claims, known and unknown, based upon, arising from, or attributable to the Policies, and (c) any and all rights and interests of the Estate in the Policies will be deemed to have been sold back to the Insurers free and clear of the interests of persons and entities in the Policies, thus permanently and irrevocably extinguishing all rights, duties, and coverage under the Policies. Pursuant to the Motion, the Trustee is also asking the court to enter an injunction that permanently enjoins the prosecution, continuation, or commencement of any Claim or Interest that any person or entity holds or asserts or may in the future hold or assert against the Insurers, based upon, arising from, or attributable to any of the Policies (the "Injunction"). Copies of the Motion and the Settlement Agreement can be obtained on the Bankruptcy Court's website (http://www.laeb.uscourts.gov/), or by contacting counsel for the Trustee or the Insurers at the addresses set forth below. YOUR RIGHTS MAY BE AFFECTED BY THE SETTLEMENT AGREEMENT AND THE ORDER APPROVING THE SETTLEMENT AGREEMENT AND ENTERING THE INJUNCTION. If you wish to object to approval of the Settlement Agreement or entry of the Injunction, you must file an objection on or by October 8, 2025. Any such objection should be filed with the Bankruptcy Court, at 500 Poydras Street, New Orleans, LA 70130, and served on the following: (i) counsel for the Trustee, Chaffe McCall, LLP, 2300 Energy Centre, 1100 Poydras Street, New Orleans, LA 70163-2300 (Attn: David J. Messina, messina@chaffe.com), and K&L Gates LLP, 1601 K Street, NW, Washington, DC 20006 (Attn: Jonathan M. Cohen, jonathan.cohen@klgates.com); (ii) the Office of the United States Trustee, 600 S. Maestri Place, Suite 840-T, New Orleans, LA 70130 (Attn: Amanda George, Amanda.B.George@usdoj.gov); and (iii) counsel for the Insurers, Roedel, Parsons, Blache, Fontana, Piontek & Pisano, a L.C., 1555 Poydras Street, Suite 1700, New Orleans, LA 70112 (Attn: Charles M. Pisano, cpisano@roedelparsons.com) and The Law Office of William J. Factor, Ltd., 105 W. Madison St., #2300, Chicago, IL 60602, (Attn: William J. Factor, wfactor@wfactorlaw.com ). PLEASE ALSO TAKE NOTICE THAT the October 15, 2025, hearing may be continued to a later date or cancelled if the Trustee so requests, without further notice except as provided on the Bankruptcy Court's website. [1] The description of the terms of the settlement contained herein is subject to the provisions of the Settlement Agreement. To the extent there is any inconsistency between the description of the terms of the settlement contained herein and the provisions of the Settlement Agreement, the provisions of the Settlement Agreement shall control. September 24 2025 LLOU0374570