Tuesday, November 09, 2010 2:13:41 AM
This is not the exact look, but this is what we will be submitting.
Dear Judge Walrath:
We submit this letter seeking joinder to the Request of Daniel Hoffman to Unseal and Post Documents for Public Viewing (Docket No. 5753), filed with the court on November 3, 2010. We are shareholders – common and/or preferred – of WMI securities and have a significant interest in the outcome of these proceedings. Moreover, we are (a.) members of the public, and (b.) injured by the non-disclosure of the contents of the sealed documents. Accordingly, we would like to join in Mr. Hoffman’s request to effectively docket and post for public viewing, the below-referenced documents:
a. the order granting the Official Committee of Equity Security Holders (the “EC”) ‘Motion for Order Authorizing the Official Committee of Equity Security Holders to File Supplemental Filing Regarding the Examiner Motion and the Scope of the Production Under Seal’, filed July 7, 2010, Docket # 4893 (the “Sealing Motion”);
b. the order granting the EC’s ‘Motion to Shorten Notice and Schedule Hearing on Motion For Order Authorizing the Official Committee of Equity Security Holders to File Supplemental Filing Regarding Examiner Motion and the Scope of the Production Under Seal’, filed July 7, 2010, Docket # 4895 (the “Motion to Shorten Time”);
c. the cover sheet for the Sealing Motion (the “cover sheet”), as required by Rule 9018-1(b) of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”);
d. the order granting the EC’s ‘Motion for Order Authorizing the Official Committee of Equity Security Holders to File Supplemental Statement in Support of Motion for Examiner and on Timing for Resolution of Shareholder Meeting Under Seal’, filed July 19, 2010. Docket # 5091 ( the “July 19th Sealing Motion”);
e. the order granting the EC’s ‘Motion to Shorten Notice and Schedule Hearing on Motion For Order Authorizing the Official Committee of Equity Security Holders to File Supplemental Statement in Support of Motion for Examiner and on Timing for Resolution of Shareholder Meeting Under Seal’, filed July 19, 2010, Docket # 5092 (the “July 19th Motion to Shorten Time”);
f. the cover sheet for the July 19th Sealing Motion (the “July 19th Cover Sheet”);
g. the document filed under seal pursuant to the Sealing Motion (the “Sealed Document”);
h. the document filed under seal pursuant to the July 19th Sealing Motion (the “July 19th Sealed Document”); and
i. the transcript of a hearing you held in your chambers on July 8, 2010 relating to the Sealed Document (the “In Camera Hearing”).
We fully support Mr. Hoffman’s request to docket and post the above-referenced documents for public viewing. Accordingly, we respectfully ask your honor to grant the request in the interests of justice, so that shareholders may reserve their rights and avail themselves of legal or equitable remedies if necessary.
Sincerely,
The Undersigned, as a group of 779 International shareholders representing:
69,701,828 Shares of WAMUQ common shares
492,823 Shares of WAMPQ Preferred Shares
2,970,713 Shares of WAMKQ Preferred Shares
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