2. Counsel is hereby requesting service at the foregoing addresses of (i) all notices
and papers referred to in Bankruptcy Rules 2002, 3017, 9007, 9010 and 1109(b), (ii) all notices of
hearings and entry of orders, (iii) every order signed in this case, and (iv) every pleading or report
filed in this case, including, without limitation, schedules, statements of affairs, operating reports,
motions, applications, complaints, demands, requests, petitions, plans of reorganization, disclosure
statements, answering or reply papers, memorandum briefs in support of any of the foregoing and
any other documents brought before this Court with respect to these proceedings, whether formal
or informal and without regard to the means by which they are transmitted or delivered.
Neither this Notice of Appearance nor any prior or later appearance, pleading, claim, or
suit shall waive any right of Simon Property Group, Inc. and its affiliates (1) to have final orders
in non-core matters entered only after de novo review by a District Court judge, (2) to trial by jury
in any proceeding so triable in this case or any case, controversy, or proceeding related to this case,
(3) to have the District Court withdraw the reference in any matter subject to mandatory or
discretionary withdrawal, or (4) to any other rights, claims, defenses, setoffs or recoupments, under
agreements, in law, in equity, or otherwise, all of which rights, claims, actions, defenses, setoffs,
and recoupments are expressly reserved.
AI
