Lehman Brothers Holdings Capital Trust III (LEHKQ)

[DJN]

C.
This Proof of Claim is directed to the following two settlement classes:
(i) All persons and entities who (1) purchased or acquired Lehman securities identified in Appendix A to the D&O Notice pursuant
or traceable to the Shelf Registration Statement and who were damaged thereby, (2) purchased or acquired any Lehman Structured
Notes identified in Appendix B to the D&O Notice pursuant to or traceable to the Shelf Registration Statement and who were damaged
thereby, or (3) purchased or acquired Lehman common stock, call options, and/or sold put options between June 12, 2007 and
September 15, 2008 through and inclusive, and who were damaged thereby (the “D&O Class”). Excluded from the D&O Class are: (i)
Defendants, (ii) Lehman, (iii) the executive officers and directors of each Defendant or Lehman, (iv) any entity in which Defendants or
Lehman have or had a controlling interest, (v) members of Defendants’ immediate families, and (vi) the legal representatives heirs,
successors or assigns of any such excluded party. Also excluded are any persons or entities who timely and validly request exclusion
from the D&O Class as set forth in the D&O Notice; and