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Ali M.M. Mojdehi, State Bar No. 123846 Christine E. Baur, State Bar No. 207811 BAKER & McKENZIE LLP 12544 High Bluff Drive, Third Floor San Diego, CA 92130-3051 Telephone: +1 858 523 6200 Facsimile: +1 858 259 8290 Counsel for the Ad Hoc Committee of Equity Holders

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE DIVISION In re: Case No. 6:07-17941-PC Chapter 11 Jointly Administered with Case No.: 6:07-17937-PC DECLARATION OF ALI M.M. MOJDEHI IN SUPPORT OF MOTION PURSUANT TO F.R.B.P. 9006(c) AND LOCAL RULE 9075-1(b) TO SHORTEN TIME OR FOR ALTERNATE DATE ON HEARING REGARDING MOTION OF AD HOC COMMITTEE OF EQUITY HOLDERS FOR RECONSIDERATION OF ORDER DENYING APPOINTMENT OF OFFICIAL COMMITTEE OF EQUITY HOLDERS

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Baker & McKenzie LLP 12544 High Bluff Drive, Third Floor San Diego, CA 92130 +1 858 523 6200

NATIONAL R.V. HOLDINGS, INC., a Delaware corporation; and NATIONAL R.V., INC., a California corporation,

I, Ali M.M. Mojdehi, hereby declare as follows: 1. I am an attorney licensed to practice law in the State of California and admitted to

practice before the United States Bankruptcy Court for the Central District of California. I am a partner in the law firm of Baker & McKenzie LLP, which serves as counsel for the Ad Hoc Committee of Equity Holders (the Ad Hoc Committee). I make these statements in support of the Ad Hoc Committees Motion pursuant to Federal Rule of Bankruptcy Procedure 9006(c) and Local

CASE NO 6:07-17941-PC (JOINTLY ADMINISTERED) MOJDEHI DECLARATION IN SUPPORT OF MOTION FOR ORDER SHORTENING TIME ON MOTION FOR RECONSIDERATION OF ORDER DENYING APPOINTMENT OF OFFICIAL COMMITTEE OF EQUITY HOLDERS SDODMS1/686992.1

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Rule 9075-1(b) to Shorten Time (Motion to Shorten Time) on the Hearing on the Motion of the Ad Hoc Committee for Reconsideration of the Order (the Order) Denying the Appointment of an Official Committee of Equity Holders in the Chapter 11 Case of National R.V. Holdings, Inc (the Motion for Reconsideration). I make these statements based on my personal knowledge and could and would competently testify thereto. 2. The Ad Hoc Committee filed the Motion for Reconsideration on March 10, 2008

seeking reconsideration of the Order, which denied the Ad Hoc Committees Motion for Appointment of an Official Committee of Equity Holders (the Motion) in the bankruptcy case of National R.V. Holdings, Inc. (the Holding Company). As detailed in the Motion for Reconsideration, the Ad Hoc Committee suggests that reconsideration of the Order is necessary because, among other things: (i) the Court did not make a factual finding as to the independent solvency of the Holding Company; and (ii) certain statements and representations made by the official committee of unsecured creditors of National R.V., Inc. at the status conference held on February 29, 2008 (the Status Conference), of which the Ad Hoc Committee was not provided notice and at which it was unrepresented, constituted an improper effort by an adverse party to influence the Courts determination of the disputed facts concerning the critical issue of each individual Debtors financial status. 3. I am currently scheduled to be in trial on April 21, 2008 before Hon. Louise DeCarl

Adler in the United States Bankruptcy Court for the Southern District of California. 4. I have reviewed the docket of the above-captioned cases. The docket reflects that a

hearing is currently set for March 26, 2008 at 10:30 a.m. regarding the Debtors Motion for an Order Authorizing Purchase of an Extension of, and Tail Coverage for, Debtors' Director and Officer Liability Insurance Policy. I believe setting a hearing on the Motion for Reconsideration for the same date and time will serve judicial economy and minimize expenses as the estate professionals, the Office of the United States Trustee, and other interested parties would likely already be before the Court.

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Baker & McKenzie LLP 12544 High Bluff Drive, Third Floor San Diego, CA 92130 +1 858 523 6200

CASE NO 6:07-17941-PC (JOINTLY ADMINISTERED) MOJDEHI DECLARATION IN SUPPORT OF MOTION FOR ORDER SHORTENING TIME ON MOTION FOR RECONSIDERATION OF ORDER DENYING APPOINTMENT OF OFFICIAL COMMITTEE OF EQUITY HOLDERS SDODMS1/686992.1

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5.

In the alternative, the Ad Hoc Committee is available on and respectfully suggests

April 1, 2008, April 2, 2008, April 7, 2008, April 8, 2008 or April 9, 2008 for an alternate hearing date. 6. On March 11, 2008, my office served the Motion for Reconsideration and all

supporting pleadings on all parties entitled to notice under the Courts Order Granting Motion Establishing Notice Procedures dated December 12, 2007 by First Class Mail. On March 12, 2008, my office served the Motion to Shorten Time and supporting documents on all parties entitled to notice under the Courts Order Granting Motion Establishing Notice Procedures dated December 12, 2007 by First Class Mail. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed this 12th day of March, 2008, in San Diego, California. /s/ Ali M.M. Mojdehi Ali M.M. Mojdehi

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Baker & McKenzie LLP 12544 High Bluff Drive, Third Floor San Diego, CA 92130 +1 858 523 6200

CASE NO 6:07-17941-PC (JOINTLY ADMINISTERED) MOJDEHI DECLARATION IN SUPPORT OF MOTION FOR ORDER SHORTENING TIME ON MOTION FOR RECONSIDERATION OF ORDER DENYING APPOINTMENT OF OFFICIAL COMMITTEE OF EQUITY HOLDERS SDODMS1/686992.1