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PACHULSKI STANG ZIEHL & JONES LLP James I. Stang, Esq. Alan J. Kornfeld, Esq. Ilan D. Scharf, Esq. 780 Third Avenue, 36th Floor New York, NY 10017-2024 Telephone: (212) 561-7700 Facsimile: (212) 561-7777 Attorneys for Official Committee of Unsecured Creditors of The Christian Brothers Institute and The Christian Brothers of Ireland, Inc. UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK Chapter 11 In re: Case No. 11-22820 (RDD) THE CHRISTIAN BROTHERS INSTITUTE, et al., (Jointly Administered) Debtors. STIPULATION REGARDING HEARING ON MOTION OF OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR AUTHORITY TO ASSERT, LITIGATE AND SETTLE CLAIMS ON BEHALF OF BANKRUPTCY ESTATE RELATING TO FRAUDULENT CONVEYANCE TO ALL HALLOWS INSTITUTE WHEREAS, the Official Committee of Unsecured Creditors (the Committee) of The Christian Brothers Institute (CBI) and The Christian Brothers of Ireland, Inc., the debtors and debtors in possession (collectively, the Debtors) in the above-captioned cases under chapter 11 of title 11 of the United States Code, filed the Committees Motion for Authority to Assert, Litigate and Settle Claims on Behalf of Bankruptcy Estate Relating to Fraudulent Conveyance to All Hallows Institute [ECF No. 302] (the Motion) on May 1, 2012; and WHEREAS, by the Motion, the Committee seeks derivative standing to prosecute an action (the Proposed Action) on behalf of CBIs bankruptcy estate to avoid and recover CBIs

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allegedly fraudulent transfer of certain real property and improvements associated with All Hallows High School (the All Hallows Property) to All Hallows Institute; and WHEREAS, CBI filed its objection [ECF No. 335] to the Motion on May 25, 2012, and the Committee filed its reply [ECF No. 339] in support of the Motion on May 30, 2012; and WHEREAS, an evidentiary hearing on the Motion is scheduled for August 6, 2012 at 10:00 a.m. EST (the Hearing); and WHEREAS, the Committee and the Debtors (collectively, the Parties) agree that (a) one of the issues to be decided by this Court (the Bankruptcy Court) in connection with the Hearing is whether the Proposed Action is likely to benefit the reorganization estate, In re STN Enterprises, 779 F.2d 901, 905 (2d Cir. 1985), and (b) in making this determination, the Bankruptcy Court is required to compare the estimated cost to CBIs bankruptcy estate of the prosecution of the Proposed Action with the estimated benefit to CBIs bankruptcy estate of the successful prosecution of the Proposed Action; and WHEREAS, in order to avoid unnecessary costs to CBIs bankruptcy estate and to narrow the issues at the Hearing, CBI and the Committee agree to stipulate to certain facts as set forth below, solely for the purpose of the Hearing. NOW THEREFORE IT IS HEREBY STIPULATED AND AGREED as follows: 1. Solely for purposes of the cost/benefit analysis to be performed by the Bankruptcy

Court in connection with the Hearing, and not for any other purpose whatsoever, the estimated cost to CBIs bankruptcy estate of the prosecution of the Proposed Action is $650,000. 2. Solely for purposes of the cost/benefit analysis to be performed by the Bankruptcy

Court in connection with the Hearing, and not as an estimate of any damages or value that may be recoverable upon successful prosecution of the Proposed Action or for any other purpose

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whatsoever, the Parties agree that the fair market value of the All Hallows Property is $8.5 million.

Dated: New York, New York July 30, 2012 TARTER KRINSKY & DROGIN LLP

Dated: New York, New York July 30, 2012 PACHULSKI STANG ZIEHL & JONES LLP

/s/ Scott S. Markowitz Scott S. Markowitz, Esq. 1350 Broadway, 11th Floor New York, New York 10018 Telephone: (212) 216-8000 Attorneys for the Debtors and Debtors in Possession

/s/ Ilan D. Scharf James I. Stang, Esq. Alan J. Kornfeld, Esq. Ilan D. Scharf, Esq. 780 Third Avenue, 36th Floor New York, NY 10017-2024 Telephone: (212) 561-7700 Attorneys for the Official Committee of Unsecured Creditors

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