Lehman Brothers Financial SA (LEHNQ)

[cottonisking]

Estate Asset Classes are Fully Resolved:

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Chapter 11 Estates would be at risk of, among other things, losing valuable tax attributes, failing
to comply with applicable securities laws, and upending the corporate governance process that has
been successful to date and was instrumental in the confirmation and effectuation of the Plan.
30. Additionally, no parties in interest will be prejudiced by the requested
governance amendments to the Plan, the certificate of incorporation, or other relevant documents.
As a result of the accomplishments of the Board of Directors and the Plan Administrator over the
past thirteen years, the remaining activities of LBHI are vastly reduced, and no longer require the
oversight of a board comprised of seven individuals with expertise in asset classes of the estate
that have been fully resolved.
Notice
31. No trustee has been appointed in these chapter 11 cases. Notice of this
Motion has been served in accordance with the procedures set forth in the second amended order
entered on June 17, 2010 governing case management and administrative procedures for these
cases [ECF No. 9635] on (i) the United States Trustee for Region 2; (ii) the Securities and
Exchange Commission; (iii) the Internal Revenue Service; (iv) the United States Attorney for the
Southern District of New York; (v) all parties who have requested notice in these chapter 11 cases;
and (vi) the Plan Trustees.

08-13555-mg Doc 61844 Filed 09/12/25 Entered 09/12/25 16:16:42 Main Document
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