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Case 20-32299-KLP Doc 1739 Filed 03/26/21 Entered 03/26/21 10:58:56 Desc Main Document Page 1 of 33 IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION ------------------------------------------------------------ x In re: : Chapter 11 : INTELSAT S.A., et al.,1 : Case No. 20-32299 (KLP) : : : Debtors. : (Jointly Administered) : ------------------------------------------------------------ x DECLARATION OF BRYAN WALSH IN CONNECTION WITH THE RETENTION OF DELOITTE LLP BY THE DEBTORS FOR TAX SERVICES I, Bryan Walsh declare as follows: 1. I am a partner of Deloitte LLP (“Deloitte Canada”), which has an office at 8 Adelaide Street West, Suite 200, Toronto, Ontario, Canada. Deloitte Canada is a subcontractor of Deloitte Tax LLP (“Deloitte Tax”). I am duly authorized to make and submit this declaration (the “Declaration”) on behalf of Deloitte Canada in support of the Debtors’ Application for Entry of an Order (I) Authorizing the Debtors to Retain and Employ Deloitte Tax LLP to Provide Tax Services to the Debtors Effective as of May 13, 2020, and (II) Granting Related Relief (the “Application”). 2 1 Due to the large number of Debtors in these chapter 11 cases, for which joint administration has been granted, 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 may be obtained on the website of the Debtors’ claims and noticing agent at https://cases.stretto.com/intelsat. The location of the Debtors’ service address is: 7900 Tysons One Place, McLean, VA 22102. 2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Application. Case 20-32299-KLP Doc 1739 Filed 03/26/21 Entered 03/26/21 10:58:56 Desc Main Document Page 2 of 33 2. The statements set forth in this Declaration are based upon my personal knowledge, information and belief, and/or client matter records kept in the ordinary course of business that were reviewed by me or other personnel of Deloitte Canada or its affiliates. 3. Subject to the foregoing, except as set forth herein and in the attachments hereto, to the best of my information, knowledge, and belief based on reasonable inquiry: (a) neither I, Deloitte Canada, nor any partner, principal, managing director of Deloitte Canada that is anticipated to provide and/or will provide the services for which Deloitte Canada is to be retained by Deloitte Tax as a subcontract (the “Engagement PPMDs”): (i) holds any interest adverse to the Debtors, and (ii) have no relationship to the Debtors, their creditors, certain other significant parties in interest, or to the attorneys that are known to be assisting the Debtors in the Chapter 11 Cases, except as stated herein or in any attachment thereto. 4. Additionally, based on searches conducted by Deloitte Canada, neither the Engagement PPMDs nor or any personnel performing services for the Debtors, or any member of such individual’s immediate family: (i) owns any director investment in the Debtor or any of the non-Debtor affiliates; (ii) holds a claim against or interest adverse to the Debtors or their non- debtor affiliates; (iii) is or was an officer, director, or employee of the Debtors or their non-debtor affiliates; (iv) is related to or has any connections to the bankruptcy judges in the Eastern District of Virginia; and (v) based on the list of individuals included on the staff directories maintained on the Office of the United States Trustee in Region 4’s website, is related to or has any connections to any such individuals working in the Office of United States Trustee for Region 4. 5. Deloitte Canada undertook a search to determine and to disclose whether it or its affiliates, is or has been employed by, or have any relationships with the entities (the “Potential Parties-in-Interest”), whose specific names were provided to Deloitte Canada by Deloitte Tax Case 20-32299-KLP Doc 1739 Filed 03/26/21 Entered 03/26/21 10:58:56 Desc Main Document Page 3 of 33 (which, I understand, were in turn provided to Deloitte Tax by the Debtors). To check upon and disclose possible relationships with significant Potential Parties-in-Interest in the Chapter 11 Cases, Deloitte Canada researched its client databases and performed reasonable due diligence to determine whether it or its affiliates had any relationships with the Debtors or the significant Potential Parties-in-Interest. 6. Deloitte Canada and its affiliates have relationships with thousands of clients, some of which may be creditors of the Debtors or other parties-in-interest. Accordingly, Deloitte Canada and/or its affiliates have had, currently have and/or may have in the future banking or other relationships with such parties, or provided, may currently provide, and/or may provide in the future professional services to certain of these parties in matters unrelated to the Chapter 11 Cases or the Debtors. Additionally, certain significant Potential Parties-in-Interest have or may have provided goods or services, may currently provide goods or services, and/or may in the future provide goods or services to Deloitte Canada and/or its affiliates and the Engagement Partners/Principals in matters unrelated to the Chapter 11 Cases or the Debtors. A listing of such parties is attached to this Declaration as Schedule 1. 7. Deloitte Canada believes that the relationships described herein or reflected on Schedule 1 have no bearing on the services for which Deloitte Canada has been subcontracted by Deloitte Tax in the Chapter 11 Cases. 8. Despite the efforts described above to identify and disclose Deloitte Canada’s connections with the significant Potential Parties-in-Interest in the Chapter 11 Cases, because Deloitte Canada is a firm with many employees, Deloitte Canada is unable to state with certainty that every client relationship or other connection has been disclosed. In this regard, if Deloitte Canada discovers additional material information that it determines requires disclosure, it will file Case 20-32299-KLP Doc 1739 Filed 03/26/21 Entered 03/26/21 10:58:56 Desc Main Document Page 4 of 33 a supplemental disclosure promptly with the Court. 9. To the best of my knowledge, based on the internal search discussed above, Deloitte Canada has determined that certain relationships should be disclosed as follows: (i) Deloitte Canada and/or its affiliates provide services in matters unrelated to the Chapter 11 Cases to certain of the Debtors’ largest unsecured creditors and other Potential Parties-in-Interest or their affiliates listed on Schedule 1. (ii) In the ordinary course of its business, Deloitte Canada and its affiliates have business relationships in unrelated matters with its principal competitors, which together with their affiliates may be Potential Parties-in-Interest in the Chapter 11 Cases. For example, from time to time, Deloitte Canada and one or more of such entities may work on assignments for the same client or may otherwise engage each other for various purposes. (iii) Certain financial institutions or their respective affiliates listed on Schedule 1 (i) are lenders to Deloitte Canada and/or (ii) have financed a portion of the capital and/or capital loan requirements of various partners and principals, respectively, of Deloitte Canada and its affiliates. (iv) Deloitte Canada has provided and continues to provide audit services to certain clients and/or their affiliates in matters unrelated to these Chapter 11 Cases. In its capacity as independent auditor, Deloitte Canada also provides such clients with ordinary course auditing services and conducts typical audit procedures that may arise from such clients’ business arrangements with the Debtors. 10. Except as may be disclosed herein, to the best of my knowledge, information, and belief, Deloitte Canada and the Engagement Partners/Principals do not hold or represent any interest adverse to the Debtors. I declare that the foregoing is true and correct. Dated: March 26, 2021 /s/ Bryan Walsh Bryan Walsh Partner Deloitte LLP Case 20-32299-KLP Doc 1739 Filed 03/26/21 Entered 03/26/21 10:58:56 Desc Main Document Page 5 of 33 Schedule 1 Potential Parties in Interest Potential parties-in-interest or their affiliates for whom Deloitte Canada or its affiliates has provided or is currently providing services in matters unrelated to the Chapter 11 Cases or the Debtors, except as set forth above, or with whom such parties have other relationships, including banking relationships. A. Bankruptcy Professionals Alvarez and Marsal Kekst and Company Kirkland & Ellis LLP PJT Partners LP B. Banks/Lender/UCC Lien Parties/Administrative Agents Abry Partners Llc ABRY Partners, LLC AEGON USA Investment Management, LLC Aequim Alternative Investments, L.P. Alcentra Limited Alcentra NY LLC AllianceBernstein Holding LP Alliancebernstein L.P AllianceBernstein, L.P. (U.S.) Allianz Global Investors U.S., LLC Allianzgi Global Investors Allstate Investment Management Company Allstate Investments, LLC Allstate Life Insurance Company Amundi Pioneer Asset Management, Inc. Antara Capital LP Apg Asset Management APG Asset Management US, Inc. Apollo Capital Management LP Apollo Credit Management, LLC Apollo Global Management, LLC Apollo Capital Management, L.P Ares Management Corporation Ares Management Llc Ares Management, LLC Aviva Investors Americas, LLC Bain Capital Credit Lp Bain Capital Credit, L.P. Bank of America Bank of America N.A. Bank Of America, N.A. Barclays Bank Plc Barclays Capital, Inc. Barings, LLC Beach Point Capital Management Lp Beach Point Capital Management, L.P. BlackRock Blackrock Advisors, Llc Case 20-32299-KLP Doc 1739 Filed 03/26/21 Entered 03/26/21 10:58:56 Desc Main Document Page 6 of 33 BlackRock Financial Management Inc BlueBay Asset Management, LLP BMO Asset Management U.S. BMO Capital Markets Bnp Paribas BNP Paribas Securities Corporation Boston Management and Research BVK- Beamtenversicherungskasse des Kantons Zurich Calamos Advisors, LLC Calamos Asset Management Inc Capital Research & Management Company (U.S.) Capital Research And Management Company Carlson Capital LP Ci Investments Inc.

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