March 11, 2010

Attn: Mr. Alex F. Morrison

Ernst & Young LLP
222 Bay Street
Toronto, Ontario M5K 1J7
Canada

Ref.: Province of Quebec, District of Montreal, No.: 500-11-036133-094

 
RE: Appointment of an Equity Committee in the AbitibiBowater, Inc., Bankruptcy
Proceedings
 
 
Dear Mr. Morrison:
 
We, the undersigned, are petitioning you to appoint a committee from the common shareholders,
referred to as an Equity Committee, for the purposes of representing the investment of those
same common shareholders in the continued bankruptcy proceedings of AbitibiBowater, Inc.
We understand that the CCAA does not specifically allow for equity committees, however
because of the international nature of this case and the reasons detailed herein, we believe it is
warranted here.

We have acted and continue to act only as a point of contact for an informal, non-represented
alliance of seventy-seven (77) different common shareholders for the purposes of making this
petition to you. This alliance of shareholders controls 10,603,876 million shares or 19.4% of the
outstanding shares of ABWTQ making this group the second largest block of outstanding
shareholders, second only to Fairfax Financial Holdings LTD.

This alliance has concerns regarding the security of its investments as the company emerges
from bankruptcy for several reasons. First, there has been a history of apparent naked shorting,
credit default swaps, and short selling causing price manipulation that has been brought to the
attention of the company and SEC, but so far no action seems to be taken and/or communicated
to us. Second, though the company has significant equity and made statements regarding
maintaining value for the shareholders there has yet to be any engagement of the common
shareholders in this reorganization process. Third, there are no preferred shares in this company
meaning the shares this alliance holds have the same priority for equity after emergence as the
Directors, Union and non-union pensioners, mutual funds, management and others. Yet, each of
those groups has been provided representation in the proceedings while we have not.

In the Thirty-Fifth Monitor Report (March 9, 2010), Hon. Mr. Justice C. Gascon, J.S.C.,
approved the ad hoc consultative committee of the non-unionized current and former employees
arguing that the Petitioners have either taken actions or have had actions imposed on them that
will impact various and diverse groups of stakeholders. The motion argues that the non-
unionized employees need a formal relationship with the Petitioners to assist in meeting the
needs of the Petitioners and mitigate the impact to the stakeholders. The common shareholders
need a formal relationship for the same reasons.

Individual shareholders have reached out to AbitibiBowater’s Investor Relations to gather

information regarding the progress of the bankruptcy case only to be told they cannot have
answers to their inquiries due to the sensitive nature of the case. The common shareholder feels
disenfranchised and alienated from the entire process. Secured creditors, unions, non-union
employees past and present, and bondholders who are well known to be partially responsible for
this bankruptcy all have representation. Yet, this alliance of common shareholders, who have the
second largest block of shares, are told time and again the equivalent of ‘no comment’. Mr.
Duane Owens, V.P. of Finance for AbitbiBowater, Inc., responded with the following when this
alliance expressed concerns over the recent trading irregularities:

“Thank you for your recent messages regarding the trading history of certain of
our securities. We intend to consider the matter internally and pursue it as we
deem appropriate under the circumstances.

Please note we do not expect to provide public updates on this matter” [email
correspondence, Tuesday, March 9, 2010]

For further understanding of the trading irregularities including naked short selling, apparent
price manipulation using short selling, and continued trading problems, we have attached a copy
of the same report sent to Mr. Owens and Mr. Alan Maza at the SEC as well as a detailed
analysis supporting this request. Each of these documents were prepared by the undersigned and
reviewed by the alliance prior to this petition.

The alliance has reviewed the situation of AbitibiBowater for evidence of the expectation of
equity after bankruptcy emergence. The company currently boasts a total Shareholder Equity
Net (according to the January, 2010, Monthly Operating Report) of $13,135,470,711 USD and
this is increasing each month. The company’s assets have increased $301,279,397 USD from
October 2009 to January 2010. In addition, the Shareholder Equity Net has increased
$142,857,584 over the same time period. Mr. Seth Kursman, AbitibiBowater, Inc., spokesperson,
was recently quoted as saying:

“After nine months of cost-cutting under the protection of U.S. and Canadian
courts, AbitibiBowater, Inc., has stacked up the cash and is ramping up to exit
bankruptcy by the middle of the year.” [Canwest News Service Friday, February
5, 2010, filed 4:31 am, with emphasis added]

We feel that the preponderance of the facts and circumstances surrounding this case dictates that
the appointment of an equity committee is reasonable, justified and necessary. Out of respect for
the court and the minimization of costs to the estate, the alliance's concerns are expressed as a
whole in this one petition. However, it is likely that the alliance member may submit their own
follow-up letters to you shortly. If needed, as members are 'parties of interest', and have a right to
be heard, individual court filings will be made.
We are very interested in the continued success of AbitibiBowater, Inc., and look forward to
supporting their emergence from bankruptcy. We are encouraged by the company’s website
stating the following:

“By delivering on our business goals and commitments, we are confident that we
can create significant long-term value for shareholders.”

An important fact not to be lost in this is that our shares and that of the alliance are the same as
all other stakeholders in this company. With this request, we are making it clear we refuse to be
discriminated against in this reorganization process. Recently, Mr. D. Patterson, CEO and
President of AbitibiBowater, was quoted as saying "It is our obligation to defend the interests of
our stakeholders and ensure we receive compensation for the fair market value of the
expropriated assets, plus additional damages” when asked about AbitibiBowater’s NAFTA
lawsuit against Newfoundland and Labrador governments. This alliance is just as much
stakeholders as union employees, non-union employees, Directors and bondholders and demand
that our rights be defended as well.

The committees currently having a formal role in this process are defending their rights and have
picked and chosen their representatives in this process. They do not necessarily represent this
alliance’s interests. We implore AbitibiBowater to not get caught up in the same practice against
which they are fighting the Canadian government. We implore you and AbitibiBowater to
accept us at the table as you have those other groups.

We anticipate a response to this request and will follow up with you shortly.

Respectfully submitted,

Elizabeth L. Romero, MSc

Dr. Henry Romero, CPE, CSP
115 Bristol Bend Lane
Dickinson, TX 77539

Attachments:

1. Equity Committee Request Report (dated March 9, 2010)

2. Analysis of Stock, Price, Shorts and Fails-To-Deliver, Rev. 2 (dated February 27, 2010)
3. Copy of email correspondence from D. Owens, V.P. Finance, AbitibiBowater, dated
March 9, 2010
March 11, 2010

Attn: Mr. David Klauder, Esq.

Office of the United States Trustee
844 King Street, Room 2207
Lockbox #35
Wilmington, DE 19899-0035

Case No.: 09-11296(KJC) Jointly Administered

RE: Appointment of an Equity Committee in the AbitibiBowater, Inc., Bankruptcy

Proceedings

Dear Mr. Klauder, Esq.:

We, the undersigned, are petitioning you to appoint a committee from the common shareholders,
referred to as an Equity Committee, for the purposes of representing the investment of those
same common shareholders in the continued bankruptcy proceedings of AbitibiBowater, Inc.,
pursuant to bankruptcy code § 1102(a)(2).

We have acted and continue to act only as a point of contact for an informal, non-represented
alliance of seventy-seven (77) different common shareholders for the purposes of making this
petition to you. This alliance of shareholders controls 10,603,876 million shares or 19.4% of the
outstanding shares of ABWTQ making this group the second largest block of outstanding
shareholders, second only to Fairfax Financial Holdings LTD.

This alliance has concerns regarding the security of its investments as the company emerges
from bankruptcy for several reasons. First, there has been a history of apparent naked shorting,
credit default swaps, and short selling causing price manipulation that has been brought to the
attention of the company and SEC, but so far no action seems to be taken and/or communicated
to us. Second, though the company has significant equity and made statements regarding
maintaining value for the shareholders there has yet to be any engagement of the common
shareholders in this reorganization process. Third, there are no preferred shares in this company
meaning the shares this alliance holds have the same priority for equity after emergence as the
Directors, Union and non-union pensioners, mutual funds, management and others. Yet, each of
those groups has been provided representation in the proceedings while we have not.

In the Thirty-Fifth Monitor Report (March 9, 2010), Hon. Mr. Justice C. Gascon, J.S.C.,
approved the ad hoc consultative committee of the non-unionized current and former employees
arguing that the Petitioners have either taken actions or have had actions imposed on them that
will impact various and diverse groups of stakeholders. The motion argues that the non-
unionized employees need a formal relationship with the Petitioners to assist in meeting the
needs of the Petitioners and mitigate the impact to the stakeholders. The common shareholders
need a formal relationship for the same reasons.
Individual shareholders have reached out to AbitibiBowater’s Investor Relations to gather
information regarding the progress of the Ch. 11 case only to be told they cannot have answers to
their inquiries due to the sensitive nature of the case. The common shareholder feels
disenfranchised and alienated from the entire process. Secured creditors, unions, non-union
employees past and present, and bondholders who are well known to be partially responsible for
this bankruptcy all have representation. Yet, this alliance of common shareholders, who have the
second largest block of shares, are told time and again the equivalent of ‘no comment’. Mr.
Duane Owens, V.P. of Finance for AbitbiBowater, Inc., responded with the following when this
alliance expressed concerns over the recent trading irregularities:

“Thank you for your recent messages regarding the trading history of certain of
our securities. We intend to consider the matter internally and pursue it as we
deem appropriate under the circumstances.

Please note we do not expect to provide public updates on this matter” [email
correspondence, Tuesday, March 9, 2010]

For further understanding of the trading irregularities including naked short selling, apparent
price manipulation using short selling, and continued trading problems, we have attached a copy
of the same report sent to Mr. Owens and Mr. Alan Maza at the SEC as well as a detailed
analysis supporting this request. Each of these documents were prepared by the undersigned and
reviewed by the alliance prior to this petition.

The alliance has reviewed the situation of AbitibiBowater for evidence of the expectation of
equity after bankruptcy emergence. The company currently boasts a total Shareholder Equity
Net (according to the January, 2010, Monthly Operating Report) of $13,135,470,711 USD and
this is increasing each month. The company’s assets have increased $301,279,397 USD from
October 2009 to January 2010. In addition, the Shareholder Equity Net has increased
$142,857,584 over the same time period. Mr. Seth Kursman, AbitibiBowater, Inc., spokesperson,
was recently quoted as saying:

“After nine months of cost-cutting under the protection of U.S. and Canadian
courts, AbitibiBowater, Inc., has stacked up the cash and is ramping up to exit
bankruptcy by the middle of the year.” [Canwest News Service Friday, February
5, 2010, filed 4:31 am, with emphasis added]

We feel that the preponderance of the facts and circumstances surrounding this Chapter 11 case
dictates that the appointment of an equity committee is reasonable, justified and necessary. Out
of respect for the court and the minimization of costs to the estate, the alliance's concerns are
expressed as a whole in this one petition. However, it is likely that the alliance member may
submit their own follow-up letters to you shortly. If needed, as members are 'parties of interest',
and have a right to be heard pursuant to 11 U.S.C.§ 1109(b), individual court filings will be
made.
We are very interested in the continued success of AbitibiBowater, Inc., and look forward to
supporting their emergence from bankruptcy. We are encouraged by the company’s website
stating the following:

“By delivering on our business goals and commitments, we are confident that we
can create significant long-term value for shareholders.”

An important fact not to be lost in this is that our shares and that of the alliance are the same as
all other stakeholders in this company. With this request, we are making it clear we refuse to be
discriminated against in this reorganization process. Recently, Mr. D. Patterson, CEO and
President of AbitibiBowater, was quoted as saying "It is our obligation to defend the interests of
our stakeholders and ensure we receive compensation for the fair market value of the
expropriated assets, plus additional damages” when asked about AbitibiBowater’s NAFTA
lawsuit against Newfoundland and Labrador governments. This alliance is just as much
stakeholders as union employees, non-union employees, Directors and bondholders and demand
that our rights be defended as well.

The committees currently having a formal role in this process are defending their rights and have
picked and chosen their representatives in this process. They do not necessarily represent this
alliance’s interests. We implore AbitibiBowater to not get caught up in the same practice against
which they are fighting the Canadian government. We implore you and AbitibiBowater to
accept us at the table as you have those other groups.

We anticipate a response to this request and will follow up with you shortly.

Respectfully submitted,

Elizabeth L. Romero, MSc

Dr. Henry Romero, CPE, CSP
115 Bristol Bend Lane
Dickinson, TX 77539

Attachments:

1. Equity Committee Request Report (dated March 9, 2010)

2. Analysis of Stock, Price, Shorts and Fails-To-Deliver, Rev. 2 (dated February 27, 2010)
3. Copy of email correspondence from D. Owens, V.P. Finance, AbitibiBowater, dated
March 9, 2010