Case 11-13603-PJW

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: BLITZ U.S.A., Inc., et al.,1 Debtors. Chapter 11 Case No. 11-13603 (PJW) (Jointly Administered)
Re: Docket Nos. 1921, 1922 & 1971

NOTICE OF FILING OF AMENDED PLAN AND DISCLOSURE STATEMENT PLEASE TAKE NOTICE that, on November 12, 2013, the above-captioned debtors and debtors-in-possession (collectively, the Debtors) and the Official Committee of Unsecured Creditors for the Debtors (the Committee, and together with the Debtors, the Plan Proponents): filed (a) the Debtors and Official Committee of Unsecured Creditors Joint Plan of Liquidation [Docket No. 1921] (the Original Plan); and (b) the Disclosure Statement for Debtors and Official Committee of Unsecured Creditors Joint Plan of Liquidation [Docket No. 1922] (the Original Disclosure Statement) with the United States Bankruptcy Court for the District of Delaware (the Court). PLEASE TAKE FURTHER NOTICE that, on November 27, 2013, the Plan Proponents filed the Joint Motion of the Debtors and the Official Committee of Unsecured Creditors for Order (A) Approving the Disclosure Statement; (B) Approving Form and Manner of Notice of Confirmation Hearing; (C) Approving Procedures for the Solicitation and Tabulation of Votes to Accept or Reject the Plan; (D) Estimating Each Blitz Personal Injury Trust Claim at $1.00 for Voting Purposes; (E) Approving Notice

The Debtors in these chapter 11 cases, along with the last four digits of each Debtors federal tax identification number, include: LAM 2011 Holdings, LLC (8742); Blitz Acquisition Holdings, Inc. (8825); Blitz Acquisition, LLC (8979); Blitz RE Holdings, LLC (9071); Blitz U.S.A., Inc. (8104); and MiamiOK LLC (2604). The location of the Debtors corporate headquarters and the Debtors service address is 309 North Main Street, Miami, OK 74354.

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and Objection Procedures in Respect Thereof and (F) Granting Related Relief [Docket No. 1971] and attached as Exhibit A thereto the proposed Order Granting the Joint Motion of the Debtors and the Official Committee of Unsecured Creditors for Order (A) Approving the Disclosure Statement; (B) Approving Form and Manner of Notice of Confirmation Hearing; (C) Approving Procedures for the Solicitation and Tabulation of Votes to Accept or Reject the Plan; (D) Estimating Each Blitz Personal Injury Trust Claim at $1.00 for Voting Purposes; (E) Approving Notice and Objection Procedures in Respect Thereof and (F) Granting Related Relief (the Proposed Disclosure Statement Order). PLEASE TAKE FURTHER NOTICE that, on December 18, 2013, the Plan Proponents filed the Debtors and Official Committee of Unsecured Creditors First Amended Joint Plan of Liquidation (the Amended Plan), a copy of which is attached hereto as Exhibit A. PLEASE TAKE FURTHER NOTICE that, on December 18, 2013, the Plan Proponents filed the Disclosure Statement for Debtors and Official Committee of Unsecured Creditors First Amended Joint Plan of Liquidation (the Amended Disclosure Statement), a copy of which is attached hereto as Exhibit B. PLEASE TAKE FURTHER NOTICE that, on December 18, 2013, the Plan Proponents filed a revised version of the proposed Order Granting the Joint Motion of the Debtors and the Official Committee of Unsecured Creditors for Order (A) Approving the Disclosure Statement; (B) Approving Form and Manner of Notice of Confirmation Hearing; (C) Approving Procedures for the Solicitation and Tabulation of Votes to Accept or Reject the Plan; (D) Estimating Each Blitz Personal Injury Trust Claim at $1.00 for Voting Purposes; (E) Approving Notice and Objection Procedures in Respect
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Thereof and (F) Granting Related Relief (the Revised Disclosure Statement Order), a copy of which is attached hereto as Exhibit C. PLEASE TAKE FURTHER NOTICE that, the Amended Disclosure Statement and Amended Plan include amendments to resolve objections of certain personal injury tort claimants, including a Plan Support Agreement, a copy of which is attached as Exhibit C to the Amended Disclosure Statement. PLEASE TAKE FURTHER NOTICE that, for the convenience of the Court and parties in interest, the Debtors also have attached the following documents hereto: (a) a blackline of the Amended Plan against the Original Plan as Exhibit D; (b) a blackline of the Amended Disclosure Statement against the Original Disclosure Statement as Exhibit E; and (c) a blackline of the Revised Disclosure Statement Order against the Proposed Disclosure Statement Order as Exhibit F.

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PLEASE TAKE FURTHER NOTICE that a hearing to consider approval of the Amended Disclosure Statement and the Revised Disclosure Statement Order is scheduled for December 18, 2013 at 11:00 a.m. (ET). Dated: December 18, 2013 /s/ Amanda R. Steele RICHARDS, LAYTON & FINGER, P.A. Daniel J. DeFranceschi (Bar No. 2732) Michael J. Merchant (Bar No. 3854) Amanda R. Steele (Bar No. 5530) One Rodney Square 920 North King Street Wilmington, Delaware 19801 Telephone: (302) 651-7700 Counsel to Blitz Acquisition, LLC, Blitz RE Holdings, LLC, Blitz U.S.A., Inc. and MiamiOK LLC (f/k/a F3 Brands LLC) -and/s/ Sean M. Beach YOUNG CONAWAY STARGATT TAYLOR, LLP Sean M. Beach (Bar No. 4070) John Dorsey (Bar No. 2988) Rodney Square 1000 North King Street Wilmington, Delaware 19801 Telephone:(302)571-6600 /s/ Kevin J. Mangan WOMBLE CARLYLE SANDRIDGE RICE, LLP Francis A. Monaco, Jr. (Bar No. 2078) Kevin J. Mangan (Bar No. 3810) 222 Delaware Avenue, Suite 1501 Wilmington, Delaware 19801 Telephone: (302) 252-4320 -andJeffrey D. Prol, Esq. Mary E. Seymour, Esq. LOWENSTEIN SANDLER LLP 65 Livingston Avenue Roseland, New Jersey 07068 Telephone: (973) 597-2500 Counsel to the Official Committee of Unsecured Creditors

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Counsel for LAM 2011 Holdings, LLC and Blitz Acquisition Holdings, Inc.

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