Lehman Brothers Financial SA (LEHNQ)

[JOVI]

Motion to Amend and Extend the Scope of the Alternative Dispute Resolution Procedures Orders for Indemnification Claims of the Debtors Against Mortgage Loan Sellers

https://document.epiq11.com/document/getdocumenstbydocket/?docketId=697034&projectCode=LBH&docketNumber=58858&source=DM

8. The Plan provides for the orderly liquidation of all the property of the Debtors,
which revested on the Effective Date for the benefit of creditors and equity holders. Postconfirmation,
the equity in LBHI is held 100% by a trust defined in the Plan as the “Plan Trust.”
The Plan Trust will liquidate the assets of the Debtors, including LBHI. See Plan § 7.4 (“The
Plan Trust shall be established on the Effective Date and shall continue in existence until the
Closing Date. . . . The Plan Trust shall exercise voting rights . . . in furtherance of the liquidation
of the Debtors and compliance with the provisions of the Plan.”)