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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE : : : : : : :

In re: ELECTROGLAS, INC., et al., Debtors.

Chapter 11 Case No. 09-12416 (PJW) (Jointly Administered)


Re: Docket Nos. 455, 482

RESERVATION OF RIGHTS OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS WITH RESPECT TO (I) THE DISCLOSURE STATEMENT FOR THE DEBTORS JOINT PLAN OF LIQUIDATION UNDER CHAPTER 11 OF THE BANKRUPTCY CODE, AND (II) THE MOTION OF DEBTORS FOR ORDER (A) APPROVING DISCLOSURE STATEMENT; (B) FIXING VOTING RECORD DATE; (C) APPROVING SOLICITATION AND VOTING PROCEDURES WITH RESPECT TO DEBTORS CHAPTER 11 PLAN; (D) APPROVING FORM OF SOLICITATION PACKAGE AND NOTICES; AND (E) SCHEDULING CERTAIN DATES IN CONNECTION THEREWITH The Official Committee of Unsecured Creditors (the Committee) of the abovecaptioned debtors and debtors-in-possession (the Debtors), through its undersigned counsel, hereby reserves its rights with respect to (I) the Disclosure Statement for the Debtors Joint Plan of Liquidation under Chapter 11 of the Bankruptcy Code (Docket No. 455) (as it may be supplemented or amended, the Disclosure Statement), and (II) the Motion of Debtors for Order (A) Approving Disclosure Statement; (B) Fixing Voting Record Date; (C) Approving Solicitation and Voting Procedures with Respect to Debtors Chapter 11 Plan; (D) Approving Form of Solicitation Package and Notices; and (E) Scheduling Certain Dates in Connection Therewith (Docket No. 482) (the Solicitation Motion). In support, the Committee respectfully states as follows:

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FACTUAL BACKGROUND 1. On July 9, 2009 (the Petition Date), each of the Debtors commenced a

Chapter 11 case by filing a voluntary petition for relief under Chapter 11 of Title 11, United States Code (the Bankruptcy Code). Each of the Debtors continues to operate its businesses and manage its properties as a debtor-in-possession pursuant to Bankruptcy Code Sections 1107(a) and 1108. 2. On July 28, 2009, the Office of the United States Trustee for the District

of Delaware appointed the Committee.1 3. On March 4, 2010, the Debtors filed the Disclosure Statement. Attached

as Exhibit A to the Disclosure Statement is the Debtors Plan of Liquidation under Chapter 11 of the Bankruptcy Code (as it may be supplemented or amended, the Plan). 4. On March 19, 2010, the Debtors filed the Solicitation Motion. RESERVATION OF RIGHTS 5. The Committee has been in discussions with the Debtors regarding certain

modifications to the Disclosure Statement and Plan. To date, those discussions have been productive. The Committee hopes that it will be in a position to support the Disclosure Statement and Solicitation Motion at the time of the hearing thereon. However, the Committee files this Reservation of Rights out of an abundance of precaution, in order to ensure that the Committee may raise any objections to the Disclosure Statement or Solicitation Motion at the time of the hearing, to the extent that such objections are not resolved consensually prior to such hearing. Additionally, the Committee reserves its rights to assert objections to the Plan once (and if) the Disclosure Statement is approved.
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The Committee consists of NPI Solutions, Inc., U-Freight America, Inc., and Execuforce LLC. 2

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Dated: April 5, 2010

WOMBLE CARLYLE SANDRIDGE & RICE, PLLC /s/ Matthew P. Ward Steven K. Kortanek (Del. Bar No. 3106) Matthew P. Ward (Del. Bar No. 4471) 222 Delaware Avenue, Suite 1501 Wilmington, DE 19801 (302) 252-4320 (telephone) (302) 252-4330 (facsimile) Counsel for the Official Committee of Unsecured Creditors

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