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Tuesday, January 18, 2011 5:35:06 PM
1. With respect to each instance in which you traded in the Debtors debt or equity while in possession of non-public information relating to the Debtors or to settlement negotiations concerning these Chapter 11 cases, identify: (i) the date of such trade(s); (ii) the amount and type of debt or equity you traded; (iii) the consideration you gave or received for the debt or equity; (iv) the type of confidential information you possessed at the time, including but not limited to the identity of the documents containing the non-public information; (v) any efforts you made to separate those with access to the confidential information from those who were involved in the decision to trade the Debtors' debt or equity; and (vi) the date(s) and circumstance(s) of your acquisition of the non-public information.
2. Identify and describe all communications you have had with third parties (including communications between Settlement Noteholders) regarding WMI, WMB, or their debt or equity.
3. Identify and describe your knowledge and role in the negotiations leading to the Global Settlement Agreement, and your knowledge and role in any other settlement negotiations concerning these Chapter 11 cases, including but not limited to the dates you participated or learned of any negotiations, the source of any knowledge of the status of the negotiations, any contribution you made to the negotiations, and any knowledge you learned about the status of the negotiations.
4. List, by type and instance of security in WMI or WMB, the profit you have made, would have made if the Debtors' Plan have been approved by the Court as presented, or anticipate making as a result of your investment in WMI or WMB debt or equity.
5. Identify and describe any internal screening and/or any other procedures you employ to ensure that your trading decisions, including trading decisions regarding any WMI or WMB debt or equity security, are not informed or affected by any confidential information in your possession.
http://www.kccllc.net/documents/0812229/0812229110118000000000004.pdf
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