WINDSTREAM HOLDINGS, INC., Et Al.,1 ) Case No

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Presentment Date: July 11, 2019 at 10:00 a.m. (prevailing Eastern Time) Objection Deadline: July 8, 2019 at 4:00 p.m. (prevailing Eastern Time) Steven J. Reisman Shaya Rochester KATTEN MUCHIN ROSENMAN LLP 575 Madison Avenue New York, NY 10022 Telephone: (212) 940-8800 Facsimile: (212) 940-8776

Conflicts Counsel to the Debtors and Debtors in Possession

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

) In re: ) Chapter 11 ) WINDSTREAM HOLDINGS, INC., et al.,1 ) Case No. 19-22312 (RDD) ) Debtors. ) (Jointly Administered) )

NOTICE OF PRESENTMENT OF STIPULATION AND ORDER EXTENDING BAR DATE TO FILE A PROOF OF CLAIM FOR FRONTIER COMMUNICATIONS CORPORATION

PLEASE TAKE NOTICE that the annexed stipulation (the “Stipulation”) will be presented for signature to the Honorable Robert D. Drain, United States Bankruptcy Judge, United States Bankruptcy

Court for the Southern District of New York (the “Court”) for approval and signature on July 11, 2019, at 10:00 a.m. (prevailing Eastern Time).

PLEASE TAKE FURTHER NOTICE that any responses or objections to the Stipulation shall:

(a) be in writing; (b) conform to the Federal Rules of Bankruptcy Procedure, the Local Bankruptcy

Rules for the Southern District of New York, all General Orders applicable to Chapter 11 cases in the

United States Bankruptcy Court for the Southern District of New York, and the Final Order Establishing

1 The last four digits of Debtor Windstream Holdings, Inc.’s tax identification number are 7717. Due to the large number of debtor entities in these chapter 11 cases, for which the Debtors have requested joint administration, a complete list of the debtor entities and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the website of the Debtors’ proposed claims and noticing agent at http://www.kccllc.net/windstream. The location of the Debtors’ service address for purposes of these chapter 11 cases is: 4001 North Rodney Parham Road, Little Rock, Arkansas 72212.

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Certain Notice, Case Management, and Administrative Procedures [Docket No. 392] (the “Case

Management Order”) approved by the Court; (c) be filed electronically with the Court on the docket of

In re Windstream Holdings, Inc., No. 19-22312 (RDD) by registered users of the Court’s electronic filing system and in accordance with the General Order M 399 (which is available on the Court’s website at http://www.nysb.uscourts.gov); and (d) be served so as to be actually received by July 8,

2019, at 4:00 p.m. (prevailing Eastern Time) (the “Objection Deadline”), by (i) the entities on the

Master Service List (as defined in the Case Management Order and available on the Debtors’ case website at http://www.kccllc.net/windstream) and (ii) any person or entity with a particularized interest in the subject matter of the Stipulation, including the Debtors and Frontier Communications

Corporation.

PLEASE TAKE FURTHER NOTICE that if no responses or objections are timely filed and served with respect to the Stipulation, the Court may approve the Stipulation, pursuant to Local

Bankruptcy Rule 9074-1, without further notice or opportunity to be heard.

Dated: June 28, 2019 /s/ Steven J. Reisman New York, NY KATTEN MUCHIN ROSENMAN LLP Steven J. Reisman, Esq. Shaya Rochester, Esq. 575 Madison Avenue New York, NY 10022-2585 Telephone: (212) 940-8800 Facsimile: (212) 940-8876 Email: [email protected] [email protected]

Conflicts Counsel to the Debtors and Debtors in Possession

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

) In re: ) Chapter 11 ) WINDSTREAM HOLDINGS, INC., et al.,1 ) Case No. 19-22312 (RDD) ) Debtors. ) (Jointly Administered) )

STIPULATION AND ORDER EXTENDING BAR DATE TO FILE A PROOF OF CLAIM FOR FRONTIER COMMUNICATIONS CORPORATION

This stipulation (the “Stipulation”) is entered into as of June 28, 2019 by and among the

above-captioned debtors and debtors in possession (collectively, the “Debtors”) and Frontier

Communications Corporation and its direct and indirect subsidiaries (“Frontier” and together with

the Debtors, the “Parties”).

RECITALS

WHEREAS, on February 25, 2019 (the “Petition Date”), each of the Debtors filed a

voluntary petition for relief under chapter 11 of title 11 of the U.S. Code, 11 U.S.C. §§ 101-1532

(as amended, the “Bankruptcy Code”) in the United States Bankruptcy Court for the Southern

District of New York (the “Bankruptcy Court”); and

WHEREAS, on May 13, 2019 the Court entered its Order (I) Setting Bar Dates for

Submitting Proofs of Claim, (II) and Approving Procedures for Submitting Proofs of Claim, and

(III) Approving Notice Thereof [Docket No. 518] (the “Bar Date Order”) setting the bar date for

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certain persons and non-governmental entities that assert a claim (as defined in section 101(5) of

the Bankruptcy Code) that arose prior to the Petition Date to submit a written proof of such claim

on or before July 15, 2019 before 4:00 p.m. (prevailing Eastern Time) (the “General Claims Bar

Date”); and

WHEREAS, Frontier provides local exchange services, including switched and special

access services to Windstream pursuant to applicable state or federal tariffs, service guides,

product guides, guidebooks, ICAs or other agreements or amendments thereto (the “Services”);

and

WHEREAS, Frontier believes it has claims against the Debtors related to Services

provided by Frontier prior to the Petition Date (collectively, “Prepetition Claims”); and

WHEREAS, the Parties are in discussions to resolve certain disputes, including disputes

related to the Prepetition Claims, and desire to enter into this Stipulation to extend the General

Claims Bar Date with respect to the Frontier’s Prepetition Claims in order to allow the Parties

additional time to continue discussions in a productive manner.

NOW, THEREFORE, the Parties, by their respective counsel, stipulate and agree as

follows:

AGREEMENT

1. The General Claims Bar Date shall be extended solely for Frontier through and

including October 14, 2019 at 4:00 p.m. (prevailing Eastern Time), solely to allow Frontier to

file proofs of claim with respect to its alleged Prepetition Claims.

2. Each person who executes this Stipulation represents that he or she is counsel for

his or her respective client and is executing this Stipulation on behalf of and with the authority of

his or her respective client. The Parties have each cooperated in drafting this Stipulation.

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Therefore, in any action or proceeding concerning this Stipulation, the provisions hereof shall be

construed as if jointly drafted by the Parties.

3. Nothing in this Stipulation should be construed as an acknowledgment or admission

that Frontier has any valid Prepetition Claim against the Debtors or that the Debtors have valid

objections or defenses to any such Prepetition Claims. Any and all rights of the Parties in

connection therewith are preserved.

4. This Stipulation is without prejudice to the Parties to seek to further extend the

General Claims Bar Date as to Frontier by the subsequent execution of another stipulation by the

Parties.

5. This Stipulation may be executed in counterparts, each of which shall be deemed

an original, but all of which together shall constitute one and the same Stipulation. The delivery

by facsimile transmission or other electronic transmission of any signature on this Stipulation shall

be a valid signature as of the transmission thereof.

6. The Parties agree to bear their own costs and fees incurred in connection with this

Stipulation.

7. Neither this Stipulation nor any of its terms may be modified, altered, amended or

waived, except in writing signed by the Parties hereto.

8. This Stipulation and all its terms and conditions shall inure to the benefit of, and be

binding on, the Parties hereto and their respective successors and assigns and no third party rights

shall be created hereunder.

9. This Stipulation is no force and effect absent approval of the Court.

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10. The Court retains exclusive jurisdiction with respect to all matters arising from or

related to the implementation, interpretation, and enforcement of this Stipulation and Order.

Dated: June 28, 2019 New York, NY

/s/ Steven J. Reisman /s/ Sean T. Scott Steven J. Reisman, Esq. Sean T. Scott Shaya Rochester, Esq. MAYER BROWN LLP KATTEN MUCHIN ROSENMAN LLP 71 South Wacker Drive 575 Madison Avenue Chicago, IL 60606 New York, NY 10022-2585 Telephone: (312) 782-0600 Telephone: (212) 940-8800 Facsimile: (312) 701-7711 Facsimile: (212) 940-8876 Email: [email protected] Email: [email protected] [email protected]

Conflicts Counsel for the Debtors and Debtors in Counsel for Frontier Communications Possession Corporation

Dated: , 2019 SO ORDERED: White Plains, NY

THE HONORABLE ROBERT D. DRAIN UNITED STATES BANKRUPTCY JUDGE