Hearing Date and Time: October 15, 2009 at 2:00 P.M. Objection Deadline: October 9, 2009 at 4:00 P.M
Hearing Date and Time: October 15, 2009 at 2:00 p.m.
Objection Deadline: October 9, 2009 at 4:00 p.m.
JONES DAY
222 East 41st Street
New York, New York 10017
Telephone: (212) 326-3939
Facsimile: (212) 755-7306
Robert W. Gaffey
Jayant W. Tambe
William J. Hine
Attorneys for Debtor
and Debtor in Possession
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
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:
In re: : Chapter 11
:
LEHMAN BROTHERS HOLDINGS INC., et al., : Case No. 08-13555 (JMP)
:
Debtors. : (Jointly Administered)
:
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NOTICE OF HEARING OF DEBTOR’S MOTION FOR AN ORDER,
PURSUANT TO FED. R. CIV. P. 60 AND FED. R. BANKR. P. 9024, MODIFYING
THE SEPTEMBER 20, 2008 SALE ORDER AND GRANTING OTHER RELIEF
PLEASE TAKE NOTICE that a hearing on the Debtor’s Motion for an Order,
Pursuant to Fed. R. Civ. P. 60 and Fed. R. Bankr. P. 9024, Modifying the September 20, 2008
Sale Order and Granting Other Relief (the “Motion”), which was filed under seal substantially
contemporaneously herewith, will be held before the Honorable James M. Peck, United States
Bankruptcy Judge, at the United States Bankruptcy Court, Alexander Hamilton Customs House,
Courtroom 601, One Bowling Green, New York, New York 10004 (the “Bankruptcy Court”), on
October 15, 2009 at 2:00 p.m. (Prevailing Eastern Time) (the “Hearing”).
PLEASE TAKE FURTHER NOTICE that objections, if any, to the Motion
shall be in writing, shall conform to the Federal Rules of Bankruptcy Procedure and the Local
Rules of the Bankruptcy Court for the Southern District of New York, shall set forth the name of
the objecting party, the basis for the objection and the specific grounds thereof, shall be filed
with the Bankruptcy Court electronically in accordance with General Order M-242 (which can
be found at www.nysb.uscourts.gov) by registered users of the Bankruptcy Court’s case filing
system and by all other parties in interest, on a 3.5 inch disk, preferably in Portable Document
Format (PDF), Microsoft Word, or any other Windows-based word processing format (with two
hard copies delivered directly to Chambers), and shall be served upon: (i) the chambers of the
Honorable James M. Peck, One Bowling Green, New York, New York 10004, Courtroom 601;
(ii) Jones Day, 222 East 41st Street, New York, New York 10017 (Attn: Robert W. Gaffey,
William J. Hine, and Jayant W. Tambe) and Weil Gotshal & Manges LLP, 767 Fifth Avenue,
New York, New York 10153 (Attn: Richard P. Krasnow, Lori R. Fife, Shai Y. Waisman, and
Jacqueline Marcus), attorneys for the Debtors; (iii) the Office of the United States Trustee for the
Southern District of New York, 33 Whitehall Street, 21st Floor, New York, New York 10004
(Attn: Andy Velez-Rivera, Paul Schwartzberg, Brian Masumoto, Linda Riffkin, and Tracy Hope
Davis); (iv) Milbank, Tweed, Hadley & McCloy LLP, 1 Chase Manhattan Plaza, New York,
New York 10005 (Attn: Dennis F. Dunne, Dennis O’Donnell, and Evan Fleck) and Quinn
Emanuel Urquhart Oliver & Hedges, LLP, 51 Madison Avenue, 22nd Floor, New York, New
York 10010 (Attn: Susheel Kirpalani and James C. Tecce), attorneys for the official committee
of unsecured creditors appointed in these cases; (v) Hughes Hubbard & Reed, LLP, One Battery
Park Plaza, New York, NY 10004 (Attn: William R. Maguire, Neil Oxford and Seth D.
Rothman), attorneys for the SIPA Trustee; (vi) Jenner & Block LLP, 919 Third Avenue, 37th
Floor, New York, New York 10022-3908 (Attn: Anton R. Valukas, Vincent E. Lazar, Robert L.
Byman, David C. Layden, and Patrick J. Trostle) attorneys for the examiner; and (vii) Boies,
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Schiller & Flexner LLP, 575 Lexington Avenue, 7th Floor, New York, New York 10022 (Attn:
Jonathan D. Schiller, Hamish P.M. Hume and Jack G. Stern), attorneys for Barclays Capital Inc.,
so as to be filed and received no later than October 9, 2009 at 4:00 p.m. (Prevailing Eastern
Time) (the “Objection Deadline”).
PLEASE TAKE FURTHER NOTICE that if an objection to the Motion is not
received by the Objection Deadline, the relief requested shall be deemed unopposed, and the
Bankruptcy Court may enter an order granting the relief sought without a hearing.
PLEASE TAKE FURTHER NOTICE that objecting parties are required to
attend the Hearing, and failure to appear may result in relief being granted or denied upon
default.
Dated: September 15, 2009 Respectfully submitted,
New York, New York
/s/ Robert W. Gaffey
Robert W. Gaffey
Jayant W. Tambe
William J. Hine
JONES DAY
222 East 41st Street
New York, New York 10017
Telephone: (212) 326-3939
Facsimile: (212) 755-7306
ATTORNEYS FOR DEBTOR AND DEBTOR
IN POSSESSION
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