Contract analysis

I. Introduction and Purpose We write on behalf of our client, Meridian Consumer Brands LLC ("Meridian" or "MCB"), a member of the Official Committee of Unsecured Creditors (the "Committee") appointed by the United States Trustee on October 28, 2025, in the above-captioned Chapter 11 case. The purpose of this letter is to set forth Meridian's priorities and negotiating positions in anticipation of plan negotiations wi

II. Background — Meridian's Claims and Relationship with the Debtor To provide appropriate context for the positions set forth below, we summarize Meridian's claims profile and its commercial relationship with Cascadia. Meridian Consumer Brands LLC. Meridian is a Delaware limited liability company with its principal offices located at 575 Lexington Avenue, 22nd Floor, New York, New York 10022. MCB is a portfolio comp

Section 503(b)(9) Administrative Expense Claim. Meridian has timely asserted a Section 503(b)(9) administrative expense claim in the amount of $1,847,200.00. This claim represents the value of goods received by the Debtor in the ordinary course of business within twenty (20) days prior to the petition date — specifically, goods received between September 24, 2025, and October 14, 2025. This administrative expense cla

III. Overview of Cascadia's Capital Structure and Unsecured Claims Pool A clear understanding of the Debtor's capital structure and the composition of the unsecured claims pool is essential to any plan negotiation. Based on information available to date — including the Debtor's First Day Declarations, schedules of assets and liabilities, and publicly available information — Meridian's understanding of the relevant ca

IV. Meridian's Plan Negotiation Positions Against this background, Meridian sets forth the following positions for incorporation into the Committee's plan negotiations. A. Enhanced Recovery for Trade Creditors Relative to Bond Claims Position. It is Meridian's position that trade creditor claims should receive enhanced or preferential recovery relative to the 8.75% Senior Unsecured Notes ($215 million outstanding) wi

V. Additional Considerations for Plan Negotiations In addition to the core plan negotiation positions set forth in Section IV, Meridian identifies the following supplemental issues that the Committee should address in plan discussions. A. Valuation and Enterprise Value Meridian requests that the Committee's financial advisor, Broadleaf Advisory Group LLC, prepare an independent valuation of Cascadia both as a going c

VI. Request for Incorporation of Positions into Committee Advocacy In light of the foregoing, Meridian respectfully requests that Garvey & Holbrook LLP incorporate the positions set forth in this letter into the Committee's plan term sheet discussions with Brindoval Baines & Lord LLP (Harrison Caldwell) and the Debtor's financial advisor, Ashworth Partners LLC (Sandra Ng). We believe that these positions reflect not

1. Strict enforcement of the absolute priority rule and opposition to any equity recovery while unsecured creditors are impaired;

2. Adequate and meaningful consideration for any third-party release provisions;

3. Full cash payment of all administrative expense claims — including Section 503(b)(9) claims and Section 503(b)(1)(A) post-petition trade claims — on the effective date of any plan; and

4. Opposition to any equity recovery absent full payment of unsecured creditor claims. Meridian is prepared to support the Committee's positions at any hearing before the Honorable Christine M. Aldridge, United States Bankruptcy Judge, and to provide testimony, declarations, or other evidentiary support as needed. Meridian's general counsel, Priya Anand, and its vice president of finance, Douglas Hargrove, are availa

VII. Closing and Contact Information We would welcome the opportunity to discuss the positions set forth in this letter with you and your team in advance of the next plan negotiation session with the Debtor's counsel. Please let us know your availability to schedule a call or in-person meeting at your earliest convenience. I am available to discuss this matter at any time. My contact information is as follows: Colett