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<br />Exhibit B - Declaration of Thomas Fairfield Page 1 of 17
<br />Exhibit B
<br />(Declaration of Thomas Fairfield)
<br />Case 1'.20-bk-12043 Doc 573-1 Filed 01/13/21 Entered 0111312111'.03'. 53 Desc
<br />Exhibit A- Declaration��thu, Young Page 9 of
<br />Case 1:20-bk-12043 Doc 573-2 Filed 01/13/21 Entered 01/13/21 1103:53 Desc Case 1:20-bk-12043 Doc 573-2 Filed 01/13/21 Entered 01/13/21 1103:53 Desc
<br />Exhibit B - Declaration of Thomas Fairfield Page 2 of 17 Exhibit B - Declaration of Thomas Fairfield Page 3 of 17
<br />IN THE UNITED STATES BANKRUPTCY COURT
<br />FOR THE SOUTHERN DISTRICT OF OHIO
<br />IN RE: I Chapter 11
<br />HOPEDALE MINING LLC, et aZ,t Case No. 20-12043 (GRH)
<br />Debtors. (Jointly Administered)
<br />DECLARATION OF THOMAS L. FAIRFIELD IN SUPPORT OF AN ORDER
<br />(I) APPROVING THE DEBTORS' DISCLOSURE STATEMENT AND
<br />(II) CONFIRMING AMENDED JOINT PLAN OF LIQUIDATION OF
<br />DEBTORS UNDER CHAPTER 11 OF THE BANKRUPTCY CODE
<br />Thomas L. Fairfield, pursuant to 28 U.S.C. § 1746, declares:
<br />1. I am the Chief Restructuring Officer ("CRO') for the above -captioned debtors and
<br />debtors -in -possession (collectively, the "Debtors"). I was appointed to the position of the
<br />Debtors' CRO on May 26, 2020. My current duties include oversight and management over all
<br />aspects of the Debtors' financial and operational matters.
<br />2. As CRO, I am familiar with the Debtors' operations and financial affairs. I am also
<br />familiar with the terms and provisions of the First Amended Joint Disclosure Statement Pursuant
<br />to Section 1125 of the Bankruptcy Code with Respect to the Joint Plan of Orderly Liquidation of
<br />Hopedale Mining LLC and its Affiliated Debtors Under Chpter 11 of the Bankruptcy Code
<br />(Docket No. 530) (as may be further amended, the "Plan")2 and the First Amended Joint Plan of
<br />` The Debtors in these Chapter 11 cases aze (with the last Pour digit, of then federnl tax identification numbers m
<br />pazentheses): Rhino GP LLC (8619), Rhino Resource Parinefs LP (7517), Rhino Energy LLC (6320), Rhino Tracking
<br />LLC (8773), Rhm. Expl.mtion LLC (8863), Triad Roof Support Systems LLC (1183), Springdale Land LLC (9816),
<br />McClsne Canyon Mining LLC (3783), Rhino Northern Holdings LLC (1858), CAM -Ohio Real Estate LLC (1859),
<br />CAMLolorndo LLC (4269), Taylorville Mining LLC (5106), CAM Coal Trading LLC (4143), Castle Valley Mining
<br />LLC (9495), Jewell Valley Mining LLC (0270), Rhino Services LLC (3356), Rhino Oilfield Services LLC (8938),
<br />Rhino Technologies LLC (0994), CAM Mining LLC (2498), Rhino Coalfield Services LLC (3924), Hopedale Mining
<br />LLC (9060), CAM -Kentucky Real Estate LLC (9089), CAM-EE LLC (9097), Leesville Land LLC (7794), CAM
<br />Aircraft LLC (5467), Pennyxile Energy LLC (6095), Rhino Eastern LLC (1457), Rockhouse Land LLC (7702),
<br />a All capitalized teens used butnot defined herein shall have the meaning sttrbuted to such terms in the Plan
<br />Orderly Liquidation ofHopedale Mining LLC and its Affiliated Debtors Under Chpter 11 of the
<br />Bankruptcy Code (Docket No. 529) (as may be further amended, the "Disclosure Statement'').
<br />3. I am duly authorized to make and submit this declaration (the "Declaration') in
<br />support of confirmation of the Plan. Unless otherwise stated, all matters set forth in this
<br />Declaration are based upon (a) my personal knowledge, (b) my review of relevant documents, (c)
<br />information supplied to me by the Debtors' professionals, (d) my views, based upon my experience
<br />and knowledge of the Debtors' business and financial condition, and/or (e) as to matters involving
<br />the Bankruptcy Code or Bankruptcy Rules or other applicable Laws, my reliance on counsel to the
<br />Debtors. If I were called upon to testify, I would testify competently to the facts set forth in this
<br />Declaration.
<br />I. BACKGROUND
<br />A. General Background on the Chapter 11 Cases
<br />4. On July 22, 2020 (the "Petition Date"), each of the Debtors filed with this
<br />Bankruptcy Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code. No
<br />request for the appointment of a trustee or examiner has been made in these Chapter 11 Cases. On
<br />July 30, 2020, the Office of the United States Trustee for the Southern District of Ohio (the "U_S.
<br />Trustee") appointed the official committee ofunsecured creditors (the "Committee") pursuant to
<br />Section 1102 of the Bankruptcy Code (Docket No. 128).
<br />5. Additional information regarding the Debtors is contained in the Declaration of
<br />Richard A. Boone in Support of First Day Motions of Debtors and Debtors -in -Possession (Docket
<br />No. 3).
<br />II. APPROVAL OF DISCLOSURE STATEMENT
<br />6. I have reviewed the Disclosure Statement sent by the Plan Proponents in connection
<br />with confirmation ofthe Plan. The Disclosure Statement contains extensive information regarding,
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