Case 2:17-cv-03921 Document 17-1 Filed 01/10/18 Page 1 of 3 PageID 209

EXHIBIT A

Case 2:17-cv-03921 Document 17-1 Filed 01/10/18 Page 2 of 3 PageID #: 210

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA
MEDIANEWS GROUP, INC. and
CHARLESTON PUBLISHING
COMPANY,
Petitioners,
v.

Civil Action No. 2:17-cv-03921
(Judge Johnston)

DAILY GAZETTE COMPANY and
DAILY GAZETTE HOLDING
COMPANY, LLC,
Respondents.

DECLARATION OF MARSHALL W. ANSTANDIG IN SUPPORT OF MOTION FOR
EXPEDITED HEARING ON MOTION TO CONFIRM ARBITRATION AWARD
Marshall W. Anstandig, declares the following under penalty of perjury:
1.

I am Senior Vice President, General Counsel and Secretary of MediaNews Group,

Inc. d/b/a Digital First Media ("MediaNews"), a Petitioner in the above-styled action.
Petitioner Charleston Publishing Company is a wholly owned subsidiary of
MediaNews.
3.

As an officer of and general counsel to Petitioner MediaNews, I am familiar with

the Petitioners' businesses and the subject matter of the above-styled civil action.

4

After this action was filed, Petitioners were informed that Respondents had

retained the firm of Dirks, Van Essen & Murray, the leading merger and acquisition firm in the
United States newspaper industry (http://dirksvanessen.com/), to sell the operating assets of the
Daily Gazette Company, including the Charleston Gazette-Mail, and associated real estate.

 Case 2:17-cv-03921 Document 17-1 Filed 01/10/18 Page 3 of 3 PageID #: 211

5.

Upon information and belief, in furtherance of the anticipated sale of the Gazette-

Mail, Respondents settled with Pension Benefit Guaranty Corporation for unfunded withdrawal
liability in order to obtain a release of its liens, leaving United Bank in the sole position of

having a priority lien on Respondents' assets.

6.

According to counsel for Respondents, as of the end of December 2017, a

successful bidder has been identified for the purchase of the Gazette-Mail, negotiations are
"proceeding apace" with regard to the terms of the transaction, and as soon as the sale of the
Gazette-Mail or its assets is complete, the Gazette-Mail and/or Respondents are expected to file
for bankruptcy.

Dated: January 10, 2018

MARSHA:
rNSTANDIG
Senior v4c£President, General Counsel,
and Secretary^
MediaNews^jrcrtipTInc. d/b/a
Digital First Media

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