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United States Bankruptcy Court Southern District of New York Hearing Date: June 17, 2010 at 9:45 a.m. (ET) Response Deadline: June 10, 2010 at 4:00 p.m. (ET) UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ) In re: ) Chapter 11 ) CHEMTURA CORPORATION, et al.,1 ) Case No. 09-11233 (REG) ) Debtors. ) Jointly Administered ) NOTICE OF HEARING ON THE DEBTORS’ TWENTY-SIXTH TIER I OMNIBUS OBJECTION TO CERTAIN PROOFS OF CLAIM (AMENDED AND SUPERSEDED, DUPLICATE, EQUITY, PAID-IN-FULL, INSUFFICIENT DOCUMENTATION, LATE- FILED AND NO LIABILITY CLAIMS) TO THE CLAIMANTS IDENTIFIED ON SCHEDULES 1-7 TO EXHIBIT A TO THE OBJECTION:2 Chemtura Corporation and its affiliated debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the “Debtors”) provide you with this notice of objection to claim(s) pursuant to the Order Establishing Procedures for Objections to Claims, dated January 20, 2010 [Docket No. 1785] (the “Objection Procedures Order”) entered by the United States Bankruptcy Court for the Southern District of New York (the “Bankruptcy Court”). You have filed one or more proofs of claim (each, a “Claim”) in the Debtors’ chapter 11 cases to which the Debtors have filed an objection (the “Objection”) (each, a “Disputed Claim”). Your Claims may be affected as a result of the Objection. Therefore, you should read this Notice and the enclosed Objection carefully. The Debtors’ personnel and representatives will be available to discuss and potentially resolve the Objection to your Disputed Claim without the need for you to file a response or attend a hearing. To facilitate such a discussion, you may call the Chemtura Restructuring Hotline at (866) 967-0261 within 14 calendar days after the date on which this Notice was served. The Debtors’ personnel will be available to handle factual inquires regarding the Objection. Legal matters, however, will be referred to the Debtors’ 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal taxpayer-identification number, are: Chemtura Corporation (3153); A&M Cleaning Products, LLC (4712); Aqua Clear Industries, LLC (1394); ASCK, Inc. (4489); ASEPSIS, Inc. (6270); BioLab Company Store, LLC (0131); BioLab Franchise Company, LLC (6709); Bio-Lab, Inc. (8754); BioLab Textile Additives, LLC (4348); CNK Chemical Realty Corporation (5340); Crompton Colors Incorporated (3341); Crompton Holding Corporation (3342); Crompton Monochem, Inc. (3574); GLCC Laurel, LLC (5687); Great Lakes Chemical Corporation (5035); Great Lakes Chemical Global, Inc. (4486); GT Seed Treatment, Inc. (5292); HomeCare Labs, Inc. (5038); ISCI, Inc. (7696); Kem Manufacturing Corporation (0603); Laurel Industries Holdings, Inc. (3635); Monochem, Inc. (5612); Naugatuck Treatment Company (2035); Recreational Water Products, Inc. (8754); Uniroyal Chemical Company Limited (Delaware) (9910); Weber City Road LLC (4381); and WRL of Indiana, Inc. (9136). 2 Pursuant to the Objection Procedures Order [Docket No. 1785], the Debtors will serve a personalized form of this notice on each claimant subject to the Objection. K&E 16777192.1 attorneys. When you contact the hotline, please have your proof(s) of claim available. Your discussions with the Debtors’ personnel or the Debtors’ attorneys may result in an agreement to settle the Objection. If you do not reach an agreement with the Debtors before the deadline to file a response to the Objection (which is June 10, 2010), you must file a response, in compliance with the procedures set forth below. Speaking with the Debtors’ personnel or the Debtors’ attorneys will not satisfy the requirement that you must reach an agreement before June 10, 2010 or file a Response and attend the Hearing, as discussed below. If you disagree with the Objection and are unable to or unwilling to consensually resolve the Objection with the Debtors, you or your attorney must (a) file a response (the “Response”) to the Objection with the Clerk of the United States Bankruptcy Court for the Southern District of New York, Alexander Hamilton Custom House, One Bowling Green, New York, New York 10004-1408 no later than June 10, 2010 at 4:00 p.m. (prevailing Eastern Time), (b) serve the Response on (i) counsel for the Debtors, Kirkland & Ellis LLP, 601 Lexington Avenue, New York, NY 10022; (fax) (212) 446-6460, Attn: Kristina Alexander, (ii) counsel to the statutory committee of unsecured creditors appointed in these chapter 11 cases, Akin Gump Strauss Hauer & Feld LLP, One Bryant Park, New York, NY 10036, Attn: Meredith Lahaie, and (iii) proposed counsel to the statutory committee of equity security holders appointed in these chapter 11 cases, Skadden Arps Slate Meagher & Flom LLP, Four Times Square, New York, NY 10036, Attn: David M. Turetsky, so that it is actually received no later than June 10, 2010 at 4:00 p.m. (prevailing Eastern Time), and (c) attend the Hearing (described below). Your Response, if any, to the Objection must be in writing and conform to the Federal Rules of Bankruptcy Procedure, the Local Bankruptcy Rules for the Southern District of New York, and the Objection Procedures Order.3 As set forth in the Objection Procedures Order, your Response must contain, at a minimum, the following: (a) the case caption and the title of the Objection to which your Response is directed; (b) your name and the official number identifying your Claim(s); (c) the description and dates of any contracts or agreements that serves as the basis of your Claim(s), if applicable; (d) a description of the product, chemical or other material for which a Debtor is responsible that serves as the basis for your Claim(s), if applicable (including for all tort claims alleging injuries resulting from exposure to chemicals or other materials), and: (i) the dates and location of exposure to such product, chemical or other material; and (ii) medical evidence connecting any alleged personal injury to the exposure to such product, chemical or other material; (e) a description of any other basis for the amount of your Claim(s); (f) a concise statement setting forth the reasons why the Bankruptcy Court should not sustain the Debtors’ objection to your Claim(s), including, but not limited to, the specific factual and legal bases upon which you will rely in opposing the Debtors’ objection; (g) a declaration of a person with personal knowledge of the relevant facts that support your Response, to the extent the Response makes factual allegations; and 3 Responses should be filed with the Bankruptcy Court electronically by registered users of the Bankruptcy Court’s case filing system (the User’s Manual for the Electronic Case Filing System can be found at www.nysb.uscourts.gov, the official website for the Bankruptcy Court) and, by all other parties in interest, on a 3.5 inch disk, in text-searchable Portable Document Format (PDF), Wordperfect or any other Windows-based word processing format (in either case, with a hard-copy delivered directly to Chambers). 2 K&E 16777192.1 (h) the name, address, telephone number and facsimile number of the person (who may be you or your legal representative) to whom counsel for the Debtors or each Committee should serve any reply to the Response. A hearing (the “Hearing”) on the Objection shall be held on June 17, 2010 at 9:45 a.m. before the Honorable Robert E. Gerber, United States Bankruptcy Judge, in Room 621 of the United States Bankruptcy Court for the Southern District of New York, Alexander Hamilton Custom House, One Bowling Green, New York, New York, 10004. You must attend the Hearing if you disagree with the relief requested in the Objection and have filed a Response. If you or your designated attorney or representative do not timely file and serve a Response in accordance with the above referenced procedures and attend the Hearing (in the absence of an agreement between you and the Debtors providing otherwise), the Court may enter an order granting the relief requested in the Objection. If you or your designated representative or attorney do file a Response and attend the Hearing, the matter will be resolved during the Hearing. Only those Responses made in accordance with the above-referenced requirements and timely filed and received by the Court and the Debtors’ and each Committee’s attorneys will be considered by the Court at the Hearing. If you fail to respond in accordance with this Notice, the Court may grant the relief requested in the Objection without further notice or hearing. Nothing in this Notice or the accompanying Objection constitutes a waiver of any claims, counterclaims, rights of offset or recoupment, preference actions, fraudulent-transfer actions, or any other bankruptcy claims against you. All parties reserve the right to assert additional objections to your proof(s) of claim. If you wish to view the Debtors’ Schedules of Assets and Liabilities, the Claims Objection Procedures Order or any other publicly filed documents in these chapter 11 cases, you can do so on www.kccllc.net/chemtura. If you have any questions about this notice or the Objection to your Disputed Claim(s), please contact the Debtors’ counsel by e-mail at [email protected], by telephone at (212) 446-5928, or in writing to Kirkland & Ellis LLP, 601 Lexington Avenue, New York, New York 10022, Attn: Kristina Alexander. Questions regarding the amount of a Claim or the filing of a Claim should be directed to the Debtors’ claims agent, Kurtzman Carson Consultants LLC at 1-866-381-9100 or www.kccllc.net/chemtura. CLAIMANTS SHOULD NOT CONTACT THE CLERK OF THE BANKRUPTCY COURT TO DISCUSS THE MERITS OF THEIR CLAIMS. 3 K&E 16777192.1 New York, New York /s/ M. Natasha Labovitz Dated: May 27, 2010 Richard M. Cieri M. Natasha Labovitz Craig A. Bruens Jennifer L. Marines KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 Counsel to the Debtors and Debtors in Possession _/s/ Gerard S.
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