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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067 TELEPHONE: (310) 407-4000

LEE R. BOGDANOFF (State Bar No. 119542) JONATHAN S. SHENSON (State Bar No. 184250) DAVID M. GUESS (State Bar No. 238241) KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 Avenue of the Stars, 39th Floor Los Angeles, CA 90067 Telephone: (310) 407-4000 Facsimile: (310) 407-9090 Bankruptcy Counsel for Debtors and Debtors In Possession Debtors' Mailing Address 3411 N. Perris Blvd. Perris, CA 92571 National R.V. Holdings, Inc.'s Tax I.D. #XX-XXX-1079 National R.V., Inc.'s Tax I.D. #XX-XXX-5022 UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE DIVISION In re NATIONAL R.V. HOLDINGS, INC., a Delaware corporation; NATIONAL R.V., INC., a California corporation, Debtors. Case No.: Chapter 11 Jointly Administered with Case No.: 6:07-17937-PC NOTICE OF MOTION AND MOTION FOR ORDER AUTHORIZING REJECTION OF CERTAIN EXECUTORY CONTRACTS AND UNEXPIRED LEASES; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF THOMAS J. MARTINI IN SUPPORT THEREOF No Hearing Required Local Bankruptcy Rule 9013-1(g) 6:07-17941-PC

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067 TELEPHONE: (310) 407-4000

TO THE HONORABLE PETER H. CARROLL, UNITED STATES BANKRUPTCY JUDGE; THE OFFICE OF THE UNITED STATES TRUSTEE; COUNSEL FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS; THE DEBTORS'

SECURED LENDERS; AND OTHER PARTIES INTEREST: PLEASE TAKE NOTICE THAT National R.V. Holdings, Inc. and National R.V., Inc., the debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the Debtors), hereby file this Notice of Motion and Motion for Order Authorizing the Rejection of Certain Executory Contracts and Unexpired Leases (the Motion). By the Motion, the Debtors request entry of an order authorizing the Debtors to reject the executory contracts and unexpired personal property leases described hereinbelow (the Rejected Leases),1 effective as of January 31, 2008 (the date this Motion was filed and served).. As the Debtors are proceeding with an orderly liquidation of their assets, they have determined that the Rejected Leases no longer have any operational value to them. The Debtors also believe that the Rejected Leases have little, if any, assignable value, and that the cost and difficulty of locating potential assignees to the various, individual Rejected Leases does not justify such efforts. By rejecting these agreements, the Debtors are cutting off any further liability of the estates. The Debtors therefore move this Court for entry of an order approving their rejection of the Rejected Leases, effective as of the date of service of this Motion. As set forth in the annexed Memorandum of Points and Authorities, there is good and sufficient cause for granting this Motion. Bankruptcy Code section 365(a) permits a debtor in possessionsubject to court approvalto reject its unexpired leases and executory contracts whenever the debtor determines that they have no value to its estate. The Debtors have

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concluded that the Rejected Leases likely have no value to their estates and could expose the

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Notwithstanding the relief sought herein, the Debtors shall and do hereby reserve the right(s) to argue that the Rejected Leases are not executory contracts or unexpired personal property leases within the meaning of section 365 of the Bankruptcy Code in connection with any objection to any claim that may be asserted by any non-debtor party to such agreement or otherwise. Moreover, in the event there is a determination that any such agreement is not an executory contract or unexpired personal property lease, the Debtors reserve the right(s) to argue that the property subject to any such agreement was abandoned effective as of the date the subject agreement would have otherwise been deemed rejected.

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067 TELEPHONE: (310) 407-4000

Debtors to unnecessary administrative liabilities. PLEASE TAKE FURTHER NOTICE that the non-debtor parties to the Rejected Leases should immediately contact the Debtors to make arrangements for the return of any equipment or other property provided to the Debtors under the Rejected Leases. The Debtors may be contacted as follows: National R.V. Holdings, Inc., Attn: David Wilson,

dwilson@nationalrv.com, 3411 N. Perris Blvd., Perris, CA 92571; Telephone: (951) 943-6007 ext. 5376; Fax: (951) 943-8498. PLEASE TAKE FURTHER NOTICE THAT this Motion is based upon the annexed Memorandum of Points and Authorities, the annexed Declaration of Thomas J. Martini, the record in these cases, including all pleadings and documents filed by the Debtors, the arguments and representations of counsel, and any oral or documentary evidence presented at or prior to the time of the hearing on the Motion. PLEASE TAKE FURTHER NOTICE that pursuant to Local Bankruptcy Rule 9013-1(g)(1), the Debtors request that the Court grant the Motion without a hearing, unless a hearing is requested by a party in interest. Pursuant to Local Bankruptcy Rule 9013-1(g)(1) any response or opposition to the Motion or a request for a hearing on the Motion must be in writing, must otherwise comply with Local Bankruptcy Rule 9013-1(a)(7), and must be filed with the Court and served upon bankruptcy counsel for the Debtors at the address set forth in the upper left-hand corner of the first page hereof no later than fifteen (15) days from the date of service of this Motion (i.e., by no later than February 14, 2008). Pursuant to Local Bankruptcy Rule 9013-1(a)(11), the failure to timely file and serve a written opposition may be deemed by the Court to be consent to the granting of the relief requested herein. [CONTINUED ON NEXT PAGE]

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067 TELEPHONE: (310) 407-4000

WHEREFORE, the Debtors respectfully request that this Court enter an order: (1) authorizing the Debtors to reject the Rejected Leases effective as of the date of filing and service of this Motion (i.e., January 31, 2008), and (2) granting to the Debtors any other relief that the Court deems necessary and appropriate.

DATED: January 31, 2008

/s/ David M. Guess DAVID M. GUESS, an Attorney with KLEE, TUCHIN, BOGDANOFF & STERN LLP Bankruptcy Counsel for Debtors and Debtors in Possession

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067 TELEPHONE: (310) 407-4000

MEMORANDUM OF POINTS AND AUTHORITIES I. BACKGROUND A. General Background.

The Debtors commenced these cases by filing voluntary petitions for relief under chapter 11 of the Bankruptcy Code on November 30, 2007 (the "Petition Date"). The Debtors filed these cases in order to conduct an orderly disposition of their assets, and to maximize the value of those assets for the benefit of the economic stakeholders of their estates. The Debtors' principal business is the manufacture and distribution of recreational vehicles throughout the United States and Canada. Since 1964, from their Perris, California facility, the Debtors have designed, manufactured, and marketed some of the industry's highest quality "Class A" gas and diesel RVs across several branded product lines, including Dolphin, Pacifica, Sea Breeze, Surf Side, Tradewinds, and Tropi-Cal. As of the Petition Date, the Debtors were the ninth largest manufacturer of "Class A" motor homes in the country. As the Debtors are proceeding with an orderly liquidation of their assets, they have determined that the Rejected Leases no longer have any operational value to them. The Debtors also believe that the Rejected Leases have little, if any, assignable value, and that the cost and difficulty of locating potential assignees to the various, individual Rejected Leases does not justify such efforts. By rejecting these agreements, the Debtors are cutting off any further liability of the estates. The Debtors therefore move this Court for entry of an order approving their rejection of the Rejected Leases, effective as of the date of service of this Motion. II. THE REJECTED LEASES By and through this Motion, the Debtors seek authority to reject the following: Master Equipment Lease Agreement, dated on or about April 7, 2002, with Citicorp Del-Lease Inc. dba Citicorp Dealer Finance relating to Linde Forklift, Model H30T, Serial Number H2X351L0793330

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067 TELEPHONE: (310) 407-4000

Master Equipment Lease Agreement, dated on or about March 27, 2002, with Citicorp Del-Lease Inc. dba Citicorp Dealer Finance relating to Linde Forklift, Model H30T, Serial Number H2X351M0884530

Equipment Lease Agreement #7299234-001, dated on or about April 5, 2004, with GE Credit Corporation relating to Sharp Copier System, Model ARM350N, Serial Number 35062927

All leases with Xerox, other than the leases for the following equipment: o o o o o Model WC 55, Serial Number NWL033636 Model WC 55, Serial Number NWL052833 Model WC 55, Serial Number NWL052846 WC M20i, Serial Number RYU416379 WC M20i, Serial Number RYU416381 III. ARGUMENT

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A.

Sound Business Reasons Support Debtors Decision to Reject the Contracts and Leases.

Bankruptcy Code section 365(a) provides that, "subject to the court's approval [a debtor in possession] may assume or reject any executory contract or unexpired lease of the debtor." 11 U.S.C. 365(a). Courts apply the "business judgment test" in determining whether a debtor in possession's proposed assumption or rejection of an executory contract or unexpired lease is appropriate under Bankruptcy Code section 365. See, e.g., Robertson v. Pierce (In re Chi-Feng Huang), 23 B.R. 798, 799-800 (B.A.P. 9th Cir. 1982); Commercial Fin. Ltd. v. Hawaii Dimensions, Inc. (In re Hawaii Dimensions, Inc.), 47 B.R. 425, 427 (D. Haw. 1985); see also Group of Institutional Investors v. Chicago, Milwaukee, St. Paul & Pacific R.R. Co., 318 U.S. 523, 550 (1943) ("[T]he question whether a lease should be rejected . . . is one of business judgment."). Under the business judgment test, if assumption or rejection would benefit the debtor's estate, the court should approve the debtor's proposed assumption or rejection. In re Hawaii Dimensions, Inc., 47 B.R. at 427 ("Under the business judgment test, a court should
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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067 TELEPHONE: (310) 407-4000

approve a debtor's proposed rejection if such rejection will benefit the estate."); accord In re ChiFeng Huang, 23 B.R. at 801. In fact, in Summit Land Co. v. Allen (In re Summit Land Co.), 13 B.R. 310 (Bankr. D. Utah 1981), the court concluded that a debtor's decision to reject a lease should be granted as a matter of course: [C]ourt approval under Section 365(a), if required, except in extraordinary situations, should be granted as a matter of course. To begin, this rule places responsibility for administering the estate with the trustee, not the court, and therefore furthers the policy of judicial independence considered vital by the authors of the Code. Second, this rule expedites the administration of estates, another goal of the Bankruptcy Reform Act. Third, the rule encourages rehabilitation by permitting the replacement of marginal with profitable business arrangements . . . ." 13 B.R. at 315. The Debtors have determined, in their business judgment, that it is in the best interests of their estates and creditors to reject the Rejected Leases. The Court should give this

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determination considerable deference. Even without this deference, the Debtors' decision to reject the Rejected Leases should be approved given the fact that the Debtors shortly will have no ongoing business operations, and that the Rejected Leases therefore have no operational value to the estates. The Debtors also have determined that the Rejected Leases likely have no value or equity that could be realized from assignment. Absent rejection, the Debtors would simply accrue unnecessary administrative obligations which they today they cannot satisfy. The Debtors request that the Court approve rejection of the Rejected Leases under section 365(a) of the Bankruptcy Code effective as of the date of filing and service of the Motion. See, e.g., Pac. Shores Dev., LLC v. At Home Corp. (In re At Home Corp.), 392 F.3d 1064, 1072 (9th Cir. 2004) (" 365(d) confers on bankruptcy courts the equitable authority to approve the rejection of a lease retroactive to the motion filing date"). This Court has the authority to enter an order rejecting the Rejected Leases that is effective as of the date on which the Motion was filed and served (i.e., January 31, 2008). See, e.g., Thinking Machines Corp. v. Mellon Fin. Svc. Corp. (In Re: Thinking Machines Corp), 67 F.3d 1021, 1028 (1st Cir. 1995); Pac. Shores Dev., LLC v At Home Corp. (In re At Home Corp.), 292 B.R. 195 (N.D. Cal. 2003).
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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067 TELEPHONE: (310) 407-4000

As noted above, the Debtors are liquidating and shortly will have no ongoing business operations. Upon service of the Motion, the non-debtor parties to the Rejected Leases will notified of the Debtors intended rejection and be directed to retrieve the equipment and property that is the subject of the Rejected Leases. Further, the property and/or services that are the subject of the Rejected Leases are of no value to the Debtors and failure to reject the Rejected Leases could result in unnecessary administrative expenses to the estates which, for the reasons already noted, these estates are likely to be unable to satisfy. Accordingly, the Debtors believe it is in the best interests of their estates and creditors to reject the Rejected Leases effective as of the date of this Motion (i.e., January 31, 2008). III. CONCLUSION WHEREFORE, the Debtors respectfully request that this Court enter an order: (1) authorizing the Debtors to reject the Rejected Leases effective as of the date of filing and service of the motion (i.e., January 31, 2008), and (2) granting to the Debtors any other relief that the Court deems necessary and appropriate.

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DATED: January 31, 2008

/s/ David M. Guess DAVID M. GUESS, an Attorney with KLEE, TUCHIN, BOGDANOFF & STERN LLP Bankruptcy Counsel for Debtors and Debtors in Possession

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067 TELEPHONE: (310) 407-4000

DECLARATION OF THOMAS J. MARTINI I, Thomas J. Martini, declare as follows: 1. I am the Chief Financial Officer and Treasurer of National R.V. Holdings, Inc.,

a Delaware corporation ("NRVH"), and the Chief Financial Officer and Treasurer of National R.V., Inc., a California corporation ("NRV"). NRVH and NRV (together, the "Debtors") are debtors and debtors in possession in the above-captioned chapter 11 cases. 2. In these capacities, and in conjunction with the efforts of other members of the

Debtors' senior management, I am involved on a day-to-day basis with all aspects of the Debtors' affairs, including business operations, strategic planning, financial reporting, human resources, legal affairs and other management activities, including the Debtors' efforts to address their current financial difficulties. 3. As a consequence, I review and work extensively with the books and records of

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the Debtors, including their business plans, financial statements and projections, business analyses and reports, contracts and other legal documents, notes and correspondence and the like. On a regular basis, I witness and/or participate in negotiations with lenders, vendors and other creditors of the Debtors, and have worked closely with personnel from all aspects of the Debtors' business operations. 4. Based upon all of the foregoing, I have developed an intimate familiarity with:

(a) the Debtors' books and records, which are maintained in the ordinary course of business under my supervision and control as custodian (and under the control of other members of senior management), (b) the Debtors' business and financial history, and their current business and financial situation, and (c) the financial and operational details of the Debtors' business operations, and (d) the recreation vehicle industry generally. 5. I submit this declaration in support of the accompanying Motion for Order

Authorizing the Rejection of Certain Executory Contracts and Unexpired Leases (the "Motion"). Except as otherwise stated herein, if called as a witness, I could and would competently testify to the matters set forth herein from my own personal knowledge.

National R.V. Holdings Inc. - U.S. Mail

ARRACHE CLARK & POTTER THOMAS S. CLARK 4800 EASTON DRIVE SUITE 114 BAKERSFIELD, CA 93309 AUDIOVOX SPECIALIZED APPLICATIONS, LLC JULIA WILLIS 53200 MARINA DRIVE ELKHART, IN 46514

Served 1/31/2008
BARACK FERRAZZANO KIRSCHBAUM & NAGELBER WILLIAM J. BARRETT 200 WEST MADISON ST., SUITE 3900 CHICAGO, IL 60606

BEST BEST & KRIEGER, LLP FRANKLIN C. ADAMS, ESQ. PO BOX 1028 RIVERSIDE, CA 92502-1028

BEST BEST & KRIEGER, LLP RICHARD T. EGGER 3500 PORSCHE WAY, SUITE 200 ONTARIO, CA 91764

BLAKELEY & BLAKELY LLP SCOTT E. BLAKELY, ESQ. 1000 QUAIL STREET, SUITE 200 NEWPORT BEACH, CA 92660

CAL. DEPT. OF INDUSTRIAL RELATIONS ATTN: JIM WARE SELF-INSURANCE PLANS 2265 WATT AVE STE 1 SACRAMENTO, CA 95825 DANNER & MARTYN, LLP DANIEL E. MARTYN, JR. 110 E. THOUSAND OAKS BLVD., SUITE 244 THOUSAND OAKS, CA 91360

CITICORP DEL-LEASE, INC. DBA CITICORP DEALER FINANCE 450 MAMARONECK AVE. HARRISON, NY 10528

COOKSEY, TOOLEN, GAGE, DUFFY & WOOG C/O RANDALL P. MROCZYNSKI, ESQ. RE FREIGHTLINER LLC 535 ANTON BOULEVARD, TENTH FLOOR COSTA MESA, CA 92626 DUANE MORRIS, LLP KATHRYN M.S. CATHERWOOD 101 WEST BROADWAY, SUITE 900 SAN DIEGO, CA 92101

DANNER & MARTYN, LLP DIANA S. PONCE-GOMEZ 110 E. THOUSAND OAKS BLVD., SUITE 244 THOUSAND OAKS, CA 91360

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FOLEY & LARDNER LLP JILL L. MURCH 321 NORTH CLARK STREET, SUITE 2800 CHICAGO, IL 60610-4764

FOLEY & LARDNER LLP KEITH C. OWENS 555 SOUTH FLOWER STREET, SUITE 3500 LOS ANGELES, CA 90071-2411

FOLEY & LARDNER LLP LARS A PETERSON 321 NORTH CLARK STREET, SUITE 2800 CHICAGO, IL 60610-4764

FRITTS FORD ATTN: JOHN A BOYD THOMPSON & COLEGATE LLP 3610 14TH STT RIVERSIDE, CA 92501 GENERAL ELECTRIC CAPITAL CORP. 1961 HIRST DRIVE MOBERLY, MO 85270

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GREENBERG TRAURIG, LLP ATTN: DAVID B KURZWEIL, ESQ. THE FORUM, 3290 NORTHSIDE PKWY STE. 400 ATLANTA, GA 30327 LANKENAU & MILLER LLP STUART J. MILLER 132 NASSAU STREET, SUITE 423 NEW YORK, NY 10038

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KLEE TUCHIN BOGDANOFF & STERN LLP ATTN DAVID M GUESS 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CA 90067

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MOLDO DAVIDSON FRAIOLI SERROR & SESTANOVICH LLP PETER A. DAVIDSON 2029 CENTURY PARK EAST, 21ST FLOOR LOS ANGELES, CA 90067 PACHULSKI STANG ZIEHL & JONES, LLP HAMID R. RAFATJOO, ESQ. 10100 SANTA MONICA BLVD., 11TH FLOOR LOS ANGELES, CA 90067-4100

NAUTICA APPAREL, INC. LISA A. WHITNEY 40 WEST 57TH STREET NEW YORK, NY 10019

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RICHARD H. BENES 716 CORDOVA STREET SAN DIEGO, CA 92107-4220

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National R.V. Holdings Inc. - U.S. Mail

SOUTHEAST OFFICE EQUIPMENT, INC. 908 MAGNOLIA AVE. AUBURNDALE, FL 33823 THE GARDNER FIRM J. CECIL GARDNER 1119 GOVERNMENT STREET POST OFFICE DRAWER 3103 MOBILE, AL 36652 WEILAND, GOLDEN, SMILEY, WANG EKVALL & STROK, AUTUMN D. SPAETH, ESQ. 650 TOWN CENTER DRIVE, SUITE 950 COSTA MESA, CA 92626 THE GARDNER FIRM M. VANCE MCCRARY 1119 GOVERNMENT STREET POST OFFICE DRAWER 3103 MOBILE, AL 36652

Served 1/31/2008

THE GARDNER FIRM MARY E. OLSEN 1119 GOVERNMENT STREET POST OFFICE DRAWER 3103 MOBILE, AL 36652 XEROX CAPITAL SERVICES, LLC P.O. BOX 660501 DALLAS, TX 75266-0501

WEILAND, GOLDEN, SMILEY, WANG EKVALL & STRO EVAN D. SMILEY, ESQ. 650 TOWN CENTER DRIVE, SUITE 950 COSTA MESA, CA 92626

XEROX CORP. PO BOX 7413 PASADENA, CA 91109-7413

XEROX CORPORATION ATTN INQUIRY DEPARTMENT 1303 RIDGEVIEW DRIVE LEWISVILLE, TX 75057

Creditors: 45

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