Lehman Brothers Financial SA (LEHNQ)

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2. Sellers. To date, LBHI have identified approximately 6,200 Sellers involving more than 70,000 mortgage loans against whom there is reasonable cause for LBHI to believe that it holds Indemnification Claims.


LBHI holds contractual claims for indemnification and/or reimbursement against
approximately 6,200 counterparties (the “Sellers”) involving more than 70,000 mortgage loans by
virtue of settlements between (i) LBHI and the Federal National Mortgage Association [Docket
No. 42153], and (ii) LBHI and the Federal Home Loan Mortgage Corporation [Docket No.
42754], this Court’s estimation of certain RMBS Trustees’ allowed claim in LBHI’s bankruptcy
[Docket No. 57785] and the allowance of certain RMBS Trustees’ claims that were settled in the
ordinary course of business (the “Indemnification Claims”). All RMBS Indemnification Claims
will be governed by this Amended ADR Order.