The Art of Vulture Investing: Adventures in Distressed Securities Management

APPENDIX 5

Objection by Schultze Asset Management to Owens Corning Disclosure Statement

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re

Chapter 11

OWENS CORNING, et al., Debtors.

Case No. 00-3837(JKF)

(Jointly Administered)

OBJECTION OF SCHULTZE ASSET MANAGEMENT, LLC TO DISCLOSURE STATEMENT WITH RESPECT TO SIXTH AMENDED JOINT PLAN OF REORGANIZATION FOR OWENS CORNING AND ITS AFFILIATED DEBTORS AND DEBTORS-IN-POSSESSION AND MOTION FOR ORDER APPROVING RIGHTS OFFERING AND RELATED MATTERS

Schultze Asset Management, LLC (Schultze), which, through its various client accounts is a holder of more than $60,000,000 in face amount of notes classified in Class 5A under the Plan (including $15,900,000 face amount of the Owens Corning 7.5% bonds due 2018; $22,575,000 face amount of the Owens Corning 7.5% bonds due 2005; $6,100,000 of the Owens Corning 7.7% bonds due 2008; $6,800,000 of the Owens Corning 7% bonds due 2009, $3,950,000 of the Owens Corning Fiber 8.875% bonds due 2002, and $4,908,000 of the Owens Corning 7.25% DM bonds due 2000), hereby submits this Objection to the Disclosure Statement With Respect to Sixth Amended Joint Plan of Reorganization for Owens Corning and its Affiliated Debtors and Debtors-In-Possession, and the Motion For Order Approving Rights Offering Subscription Procedures and Related Matters,1 and in support thereof, respectfully represents ...