In re: AIR CARGO, INC., Chapter 11, Debtor.

Case No.: 04-37512 (JS).United States Bankruptcy Court, D. Maryland, (Baltimore Division).
March 5, 2007

Stephen F. Fruin, Bar No. 08456, Stephen B. Gerald, Bar No. 26590, Whiteford, Taylor Preston L.L.P., Baltimore, MD, Counsel for the Litigation Trustee.

Valerie P. Morrison (Bar No. 24770), H. Jason Gold, Esquire Dylan G., Trache, Esquire WILEY REIN LLP, McLean, Virginia, Counsel to Swissport Cargo Services, LP and Swissport Canada Handling, Inc.

STIPULATION REGARDING PROOFS OF CLAIM OF SWISSPORT CANADA HANDLING, INC. AND SWISSPORT CARGO SERVICES, LP (Claim Nos. 104 117)
JAMES SCHNEIDER, Bankruptcy Judge

Martin T. Fletcher, the Litigation Trustee for the bankruptcy estate of Air Cargo, Inc. (the “Litigation Trustee”), Swissport Canada Handling, Inc., and Swissport Cargo Services, LP (collectively, “Swissport”), by their respective counsel, hereby stipulate as follows:

1. On December 7, 2004, Air Cargo, Inc., the above-captioned debtor (the “Debtor”), filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

2. On May 11, 2006, the Court entered an Order (the “Confirmation Order”) approving the proposed Joint Disclosure Statement and confirming the Joint Plan of Liquidation (the “Joint Plan”).

3. On May 26, 2006 (the “Effective Date”), the Joint Plan became effective.

4. Pursuant to the Joint Plan, Martin T. Fletcher was appointed as the Litigation Trustee to liquidate all assets of the estate, including but not limited to prosecution of all claims of the estate and all claims contributed to the Litigation Trust pursuant to the Joint Plan,

5. On March 9, 2005, Swissport Canada Handling, Inc. filed proof of claim no. 104 (“Claim No. 104”), which asserts a general unsecured nonpriority claim in the total amount of $14,263.14.

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6. On March 23, 2005, Swissport Cargo Services, LP filed proof of claim no. 117 (“Claim No. 117”, together with Claim No. 104, the “Claims”), which asserts a general unsecured nonpriority claim in the total amount of $86,100.99

7. On January 23, 2006, the Litigation Trustee filed his First Omnibus Objection to Allowance of Certain Claims (the “Objection”). The Objection objected to, among other claims, the Claims.

8. Swissport’s deadline to file a response to the Objection is currently Thursday, February 22, 2007.

9. The Litigation Trustee has agreed to extend Swissport’s deadline to file a response to the Objection through and including March 12, 2007.