Common use of Notice of the Motion Clause in Contracts

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old Republic’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC THE TIG PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC THE TIG PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old Republic’s the TIG Parties’ expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH WAUSAU AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH WAUSAU AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old RepublicWausau’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AMERICAN CENTENNIAL AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AMERICAN CENTENNIAL AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old RepublicAmerican Centennial’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC THE HARTFORD PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC THE HARTFORD PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old Republic’s the Hartford Parties’ expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such Page 7 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH THE CNA PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old Republic’s expensethe CNA Parties’ expense (or as such expenses may be shared Page 8 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH THE CNA PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES jointly by the CNA Parties with other settling insurers in accordance with Paragraph 4.1 of the Agreement), of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the OneBeacon Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH ONEBEACON AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy theBankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old RepublicOneBeacon’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010. Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH ONEBEACON AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH WESTPORT AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old RepublicWestport’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010. Page 7 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH WESTPORT AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES Sound Business Judgment and Reasonableness

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be Munich Re Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH MUNICH RE AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Munich Re Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH MUNICH RE AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old RepublicMunich Re’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be Stonewall Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH STONEWALL AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH STONEWALL AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old RepublicStonewall’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs as of January 30, 2010 including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH THE CHARTIS COMPANIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old Republic’s the Chartis Companies’ expense, of the Motion and the Hearing in the national edition of the USA Today on ------------April 22, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without Mutual Marine Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC MUTUAL MARINE AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a Mutual Marine Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC MUTUAL MARINE AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old RepublicMutual Marine’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be Transport Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH TRANSPORT AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH TRANSPORT AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old RepublicTransport’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ NJ Guaranty Settlement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH THE NJ GUARANTY PARTIES Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities Entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old Republic’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC THE NAVIGATORS MANAGEMENT COMPANY PARTICIPATING PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH THE NAVIGATORS MANAGEMENT COMPANY PARTICIPATING PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old Republic’s the Navigators Management Company Participating Parties’ expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be LMC Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH THE LONDON MARKET COMPANIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH THE LONDON MARKET COMPANIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old Republic’s the London Market Companies’ expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.

Notice of the Motion. E. The Debtors have provided due and adequate notice of the Motion, the Hearing, the Agreement and the subject matter thereof to all parties in interest Old Republic Settlement Agreement Page 5 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC THE HARTFORD PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES pursuant to Bankruptcy Rules 2002 and 6004. Such notice was good and sufficient under the particular circumstances, and no further notice is necessary. Without limiting the generality of the foregoing, adequate notice of the Motion, the Hearing and the Agreement has been provided, and a reasonable opportunity to object or be heard with respect to the Motion and the relief requested therein has been afforded, to all parties in interest, including without limitation (i) the Asbestos Claimants’ Committee appointed in the Bankruptcy Case (the “Committee”); (ii) the Futures Representative appointed in the Bankruptcy Case; (iii) all known Asbestos Plaintiffs including (a) all claimants or counsel for claimants who have voted on any proposed plan of reorganization submitted by the Debtors, and (b) all such claimants who are known to the Debtors through participation in the Bankruptcy Case, the filing of a pre-petition lawsuit, or otherwise; (iv) the Claimants’ Counsel (as defined in the Plan); (v) the Collateral Trustee (as defined in the Plan) of the Congoleum Collateral Trust; (vi) all existing or former parties in the Coverage Action; (vii) all other entities known by the Congoleum Parties to have provided general liability insurance to the Congoleum-Related Parties prior to 1990; (viii) all Old Republic Settlement Agreement Page 6 Debtors: Congoleum Corporation, et al. Case No.: 09-04371 (JAP)/Chapter 11 No. 03-51524 (Jointly Administered) Caption of Order: ORDER APPROVING SETTLEMENT AGREEMENT WITH OLD REPUBLIC THE HARTFORD PARTIES AND AUTHORIZING THE SALE OF INSURANCE POLICIES FREE AND CLEAR OF LIENS, CLAIMS, INTERESTS AND OTHER ENCUMBRANCES other Insureds known to the Congoleum Parties; (ix) the United States Trustee; and (x) all other Persons or entities that, as of the date the Motion was filed, had filed a notice of appearance and demand for service of papers in the Bankruptcy Case or were otherwise listed on the master service list maintained by the Debtors in the Bankruptcy Case. In addition, to ensure the broadest notice possible, Debtors published notice, at Old Republic’s expense, of the Motion and the Hearing in the national edition of the USA Today on ------------, 2010.and