New Equity of New York Construction Company

Sale of new equity of the reorganized Debtor (Navillus Tile, Inc., d/b/a Navillus Contracting, as debtor and debtor-in-possession (“Navillus” or the “Debtor”). The Plan provides for the reorganization of Navillus as a going concern funded by cash on hand, a potential exit facility, the issuance of certain unsecured notes and/or the New Capital Contribution.

The Plan incorporates a proposal global resolution of outstanding issues between the Debtor and Liberty Mutual Insurance Company (“Liberty”), Navillus’ surety and post-petition lender, that will enable Navillus to reorganize as a going concern with Liberty’s support for ongoing operations.