ORDER CONCERNING COMMUNICATION FROM CONCERNED PARENT

The Court received the attached email today from a parent raising complaints and allegations regarding Mr. Kiran Kulkarni and Casa Laxmi, an entity that was a proposed debtor-in-possession ("DIP") lender to the debtor. An officer or principal of Casa Laxmi also signed Debtor's petition. The petition was filed on Friday, May 16. On Tuesday, May 20, 2025, following a hearing to consider a request for approval of emergency DIP financing from Casa Laxmi, the Court issued an oral ruling followed by a written order denying the application without prejudice to renewal, either in modified form or backed by additional evidence establishing that the application meets all applicable requirements. The basis for the ruling was the debtor's failure to establish that its proposed new financing adequately protected the interests of Debtor's pre-petition secured lender, but, for financing to be approved, additional requirements also would need to be met. See, e.g., In re LATAM Airlines Grp. S.A., 620 B.R. 722, 769-777 (Bankr. S.D.N.Y. 2020).

Substantive communications to the Court should be filed on the Court's docket.

Any party in interest is welcome to make submissions or be heard by the Court.

So ordered.

Dated: New York, New York

May 29, 2025

s/ David S. Jones

Honorable David S. Jones

United States Bankruptcy Judge

Lynda Calderon

From: Miles Lindahl <[redacted]com>

Sent: Thursday, May 29, 2025 3:04 PM

To: NYSBdb_jones.chambers

Subject: Additional Information Regarding Case Number 25-11009 (DSJ)

CAUTION - EXTERNAL:

Dear Judge Jones,

Your honor, I feel the need to inform you of what happened last night at a meeting between Kiran Kulkarni of Casa Laxmi and nearly 200 concerned parents and community members from Manhattan Country School. In the meeting, Mr. Kulkarni laid out an incomplete and inaccurate picture of both the current and past situations facing the school, as well as displaying willful ignorance when presented with direct questions such as, "where has the money for the payroll been coming from?" To which he responded, "I don't know, the bank?".

He challenged a creditor on debt-structure. He gave a lecture on the court system to the former head of the Federal Bar Association. He said the school would be open through next week, but—if his proposed 12% loan isn't approved—"teachers won't get paid [for it]. What do you want me to say?" At one point, he claimed that he had never intended to provide financial support to the school, saying that what he offered was "expertise", despite demanding total and complete control over the school.

Many in the parent and teacher community believe that Mr. Kulkarni intentionally delayed the bankruptcy filing to ensure the payroll budget was depleted, in order to strengthen the urgency of his request and pressure the Court. If true, this tactic has put teachers, students, and families at risk and has already forced the school administration to cut the school year short by one week.

Mr. Kulkarni has no experience with K-8 schools. He has no experience operating a non-profit in the state of New York. He appears to have little to no knowledge of labor, contract, or incorporation law. What "expertise" could he possibly bring?

His actions displayed the characteristics of a person who is—at best—delusional. At worst? Deranged.

And while there certainly could (and probably should) be an investigation into how former MCS Board Chair Roxanne Elings oversaw MCS finances, as well as how she selected Casa Laxmi as a way to bring "financial stability" to the school, let me get back to the matter at hand; my top priority is ensuring that the teachers and staff receive the pay they deserve, have worked so hard for, and are contractually obligated to receive. If Mr. Kulkarni's predatory loan needs to be approved for that to happen, so be it, but please place the most severe restrictions you can on Kiran Kulkarni and Casa Laxmi. I am just one parent with one voice, but I would rather see this matter be handled by the court and its officers than by someone who has displayed little competency and a complete lack of interest in this school and its mission.

If Manhattan Country School—a school and community truly loved and cared for by so many—must die, please don't let it be in the hands of one of the killers.

Respectfully yours,

Miles Lindahl

Parent of Current Kindergartener (5-6s)

Member of a Family that Put Down a Deposit for a School that Likely Won't Exist Next Year

[Redacted]

CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening attachments or clicking on links.