Lehman Brothers Financial SA (LEHNQ)

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Below you will see item 8 from Rex Wu's motion filed on April 8, 2019 for our CTs. (Docket #59614)

"8. LBHI and JPMCB/JPMSI are codebtors and thus affiliates in this
bankruptcy via common control. JPMCB/JPMSI guaranteed the claims of all of its affiliates with LBHI's September 9, 2008 Guarantee and
Security Agreement. Therefore, my CTs guaranteed claims are parity
with the CTs held by JPMSI or JPMCB affiliates per the CTs relevant
prospectus. (Docket #59555)"


1) Supporting basis for item 8 above:

*** LBHI's AND JPMCB's SETTLEMENT AGREEMENT DATED 2/1/2017 - Docket 54683 page 25 of 53 ***


"“Unaffected Matters” means claims filed by or on behalf of any JPMorgan Entity
or any affiliates or funds of a JPMorgan Entity, or in which any JPMorgan Entity or any
affiliates or funds of a JPMorgan Entity has an interest, that are not Settled Matters,
including without limitation claims filed by or on behalf of a JPMorgan Entity as agent,
for a customer or for a fund that it manages, claims relating to Canary Wharf, claims held
from time to time by a JPMorgan Entity’s distressed claims trading desk, and any other
claims that JPMorgan did not assert were covered by LBHI’s August and September
2008 guaranties and security agreements in favor of JPMCB’s subsidiaries and affiliates.

For the avoidance of doubt, claims relating to the LBSF Action are not Unaffected
Matters. Lehman reserves all objections and defenses to the Unaffected Matters."