PUBLIC NOTICE OF IMPORTANT DEADLINES: GST AUTOLEATHER, INC., ET AL.

KIRKLAND & ELLIS & PACHULSKI STANG ZIEHL & JONES ANNOUNCE NOTICE OF Combined hearing in the Chapter 11 bankruptcy cases of GST AUTOLEATHER, INC., et al to consider confirmation of the chapter 11 plan and adequacy of the disclosure statement filed by the debtors and related voting and objection deadlines.

BACKGROUND

1. The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, include: GST AutoLeather, Inc. (5289); GST AutoLeather Cayman I Ltd. (n/a); GST AutoLeather Cayman II Ltd. (n/a); GST AutoLeather HoldCo Corp. (4266); GST Innovations, LLC (5563); and Strategic Financial LLC (n/a). Collectively, these companies are referred to in this notice as the “Debtors.”
2. Debtors’ chapter 11 cases are pending as Case No. 17-12100 (LSS) in the United States Bankruptcy Court for the District of Delaware (the “Court”).
3. The location of the Debtors’ service address is: 20 Oak Hollow Drive, Suite 300, Southfield, Michigan 48033.

THE COMBINED HEARING ORDER

4. On March 12, 2018, the entered an order [Docket No. 625] (the “Combined Hearing Order”):
   • authorizing GST AutoLeather, Inc. and its affiliated debtors and debtors in possession (collectively, the “Debtors”), to solicit acceptances for the Joint Chapter 11 Plan of GST AutoLeather, Inc. and its Debtor Affiliates (as modified, amended, or supplemented from time to time, the “Plan”);1
   • conditionally approving the Disclosure Statement for the Joint Chapter 11 Plan of GST AutoLeather, Inc. and its Debtor Affiliates (the “Disclosure Statement”) as containing “adequate information” pursuant to section 1125 of the Bankruptcy Code;
   • approving the solicitation materials and documents to be included in the solicitation packages (the “Solicitation Packages”); and
   • approving procedures for soliciting, receiving, and tabulating votes on the Plan and for filing objections to the Plan.
5. The hearing at which the Court will consider Confirmation of the Plan and the adequacy of the Disclosure Statement (the “Combined Hearing”) will commence at on April 25, 2018, at 2:00 p.m. prevailing Eastern Time, before the Honorable Judge Laurie Selber Silverstein, in the United States Bankruptcy Court for the District of Delaware, located at 824 Market Street, 6th Floor, Wilmington, Delaware 19801.
6. The combined hearing may be continued from time to time by the Court or the Debtors without further notice other than by such adjournment being announced in open court or by a notice of adjournment filed with the Court and served on all parties entitled to notice.

Critical Information Regarding Voting on the Plan

7. Voting Record Date. The voting record date is March 12, 2018 (the “Voting Record Date”), which is the date for determining which holders of Claims in Classes 4, 5, and 6 are entitled to vote on the Plan.
8. Voting Deadline. The deadline for voting on the Plan is on April 16, 2018, at 4:00 p.m., prevailing Eastern Time (the “Voting Deadline”). If you received a Solicitation Package, including a Ballot and intend to vote on the Plan you must: (a) follow the instructions carefully; (b) complete all of the required information on the ballot; and (c) execute and return your completed Ballot according to and as set forth in detail in the voting instructions so that it is actually received by the Debtors’ notice and claims agent, Epiq Bankruptcy Solutions, LLC (the “Notice and Claims Agent”) on or before the Voting Deadline. A failure to follow such instructions may disqualify your vote.

Critical Information Regarding Objecting to the Plan

9. Article VIII of the Plan contains release, exculpation, and injunction provisions, and article VIII.D contains a third party release. Thus, you are advised to review and consider the plan carefully because your rights might be affected thereunder.
10. Objection Deadline. The deadline for filing objections to the Plan and adequacy of the Disclosure Statement is April 17, 2018, at 4:00 p.m., prevailing Eastern Time (the “Objection Deadline”). All objections to the relief sought at the Combined Hearing must: (a) be in writing; (b) conform to the Bankruptcy Rules, the Local Rules, and any orders of the Court; (c) state, with particularity, the legal and factual basis for the objection and, if practicable, a proposed modification to the Plan (or related materials) that would resolve such objection; and (d) be filed with the Court (contemporaneously with a proof of service) and served upon the following parties so as to be actually received on or before the Objection Deadline:
    • Co-Counsel to the Debtors
      • KIRKLAND & ELLIS LLP.
        KIRKLAND & ELLIS INTERNATIONAL LLP
        James H.M. Sprayregen, P.C.
        Ryan Blaine Bennett (admitted pro hac vice)
        Benjamin M. Rhode (admitted pro hac vice)
        Alexandra Schwarzman (admitted pro hac vice)
        300 North LaSalle
        Chicago, Illinois 60654
        Telephone: (312) 862-2000
        Facsimile: (312) 862-2200
        Email: [email protected]
        [email protected]
        [email protected]
        [email protected]
        Laura Davis Jones (No. 2436)
        Timothy P. Cairns (No. 4228)
        Joseph M. Mulvihill (No. 6061)
      • PACHULSKI STANG ZIEHL & JONES LLP
        919 North Market Street, 17th Floor
        P.O. Box 8705
        Wilmington, Delaware 19899-8705 (Courier 19801)
        Telephone: (302) 652-4100
        Facsimile: (302) 652-4400
        Email: [email protected]
        [email protected]
        [email protected]
    • Co-Counsel to the Creditors’ Committee
      • WHITEFORD, TAYLOR & PRESTON LLC
        Christopher M. Samis (No. 4909)
        L. Katherine Good (No. 5101)
        Aaron Stulman (No. 5807)
        The Renaissance Centre
        405 North King Street, Suite 500
        Wilmington, Delaware 19801
        Telephone: (302) 353-4144
        Facsimile: (302) 661-7950
      • FOLEY & LARDNER LLP
        Erika L. Morabito (admitted pro hac vice)
        Brittany J. Nelson (admitted pro hac vice)
        Washington Harbour
        3000 K. Street, N.W., Suite 600
        Telephone: (202) 295-4791
        Facsimile: (202) 672-5399
    • Counsel to the First Lien Credit Facility
      • PAUL HASTINGS LLP
        Andrew V. Tenzer (admitted pro hac vice)
        200 Park Avenue
        New York, New York 10166
        Telephone: (212) 318-6099
        Facsimile: (212) 230-7699
    • a.Counsel to the Mezzanine Credit Facility
      • MCGUIRE WOODS LLP
        Douglas M. Foley (admitted pro hac vice)
        2001 K Street, N.W., Suite 400
        Washington, D.C. 20006
        Telephone: (202) 857-1720
        Facsimile: (202) 828-3301
    • U.S. Trustee
      • Office of the United States Trustee
        The District of Delaware
        844 King Street, Suite 2207
        Wilmington, Delaware 19801
        Attn: Timothy J. Fox, Esq.

ADDITIONAL INFORMATION

11. Obtaining Solicitation Materials. The materials in the Solicitation Package are intended to be self-explanatory. If you should have any questions or if you would like to obtain additional solicitation materials (or paper copies of solicitation materials if you received a CD-ROM), please feel free to contact the Debtors’ Notice and Claims Agent, by: (a) calling the Debtors’ restructuring hotline at (866) 897-6433 (toll free) or (646) 282-2500 (international) and requesting to speak with a member of the Solicitation Team; (b) visiting the Debtors’ restructuring website at: http://dm.epiq11.com/GAL; and/or (c) writing to GST AutoLeather, Inc. c/o Claims Processing Center, 10300 SW Allen Blvd., Beaverton, Oregon 97005; and/or (d) emailing [email protected] with a reference to “GST AutoLeather” in the subject line. You may also obtain copies of any pleadings filed in the Chapter 11 Cases for a fee via PACER at: http://www.deb.uscourts.gov. Please be advised that the Notice and Claims Agent is authorized to answer questions about, and provide additional copies of, solicitation materials, but may not advise you as to whether you should vote to accept or reject the Plan.
12. The Plan Supplement. The Debtors will file the Plan Supplement (as defined in the Plan) on or before April 6, 2018, and will serve notice on all holders of Claims entitled to vote on the Plan, which will: (a) inform parties that the Debtors filed the Plan Supplement; (b) list the information contained in the Plan Supplement; and (c) explain how parties may obtain copies of the Plan Supplement. The Plan Supplement will be available on the Debtors’ restructuring website at: http://dm.epiq11.com/GAL.

BINDING NATURE OF THE PLAN

13. If confirmed, the Plan shall bind all holders of claims and interests to the maximum extent permitted by applicable law, whether or not such holder will receive or retain any property or interest in property under the plan, has filed a proof of claim in the chapter 11 cases or failed to vote to accept or reject the plan or voted to reject the plan.

AUTHORITY TO PUBLISH THIS NOTICE

14. Co-Counsel to the Debtors first issued this notice on March 14, 2018 and publish it herein pursuant to the Combined Hearing Order.