The Motion
Lehman Brothers Holdings Inc. (the “Plan Administrator”), as Plan Administrator under the Modified Third Amended Joint Chapter 11 Plan of Lehman Brothers
Holdings Inc. and Its Affiliated Debtors , on behalf of Lehman Brothers Special Financing Inc.,
pursuant to Rule 9019 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”)
for approval of a settlement agreement between LBSF and The Bank of New York Mellon Trust Company, National Association, as Trustee (the “Trustee”), relating to a credit default swap agreement in connection with the MKP Vela CBO transaction, all as more fully described in the
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(Note)
In keeping with the confidentiality provisions of the Settlement Agreement, and due to LBHI’s and LBSF’s desire to keep the economic terms of the Settlement Agreement confidential, the Settlement Agreement is not included as an exhibit to this Motion. The Plan Administrator will provide the Settlement Agreement to the Court, the U.S. Trustee, and the attorneys for the official committee of unsecured creditors appointed in these cases. Noteholders and Preference Shareholders must contact the Trustee for copies of the Settlement Agreement and, before receiving any such copy, such Noteholders or Preference Shareholders will be required to execute an agreement binding them to the confidentiality restrictions of the Settlement Agreement, including paragraph 13 of the SPV ADR Procedures Order
By this Motion, the Plan Administrator, on behalf of LBSF, seeks
approval, pursuant to Rule 9019(a)
RULE 9019. COMPROMISE AND ARBITRATION
(a) Compromise. On motion by the trustee and after notice and a hearing, the court may approve a compromise or settlement. Notice shall be given to creditors, the United States trustee, the debtor, and indenture trustees as provided in Rule 2002 and to any other entity as the court may direct.
Rule 2002. Notices to Creditors, Equity Security Holders, Administrators in Foreign Proceedings, Persons Against Whom Provisional Relief is Sought in Ancillary and Other Cross-Border Cases, United States, and United States Trustee
The Motion
For authorization for Lehman Brothers Special Financing Inc. and Lehman Brothers
Commercial Corporation Inc. to invest disputed claims reserves for claim numbers 66455 and 66476
The Claims
66455
66476 (See Exhibit C page 16 of this claim)
AI
