Old Copper Co. Inc. (f/k/a CPPRQ/JCPNQ JC Penney)

[thelionwarrior]

. The Declaration reveals that Kirkland has connections with several Parties in
Interest that are potential M&A counterparties. The Declaration provides in part that “The Debtors
are in discussions with certain parties (and may be in discussions with other parties in the future)
regarding potential M&A transactions regarding the Debtors and their businesses. Due to the
inherently competitive nature of this process, it is imperative that the identities of these potential
counterparties remain confidential.”