Mr Cooper Group Inc (COOP)

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REQUESTS FOR PRODUCTION OF DOCUMENTS

1. All documents or communications concerning your past and present ownership of WMI, WMB, and/or the Debtors' debt or equity, including: (i) the amount and type of such debtor equity owned; (ii) the date(s) on which such debt or equity were purchased by you; (iii) the purchase price of such debt or equity; (iv) the date(s) on which such debt or equity were sold byyou; (v) the sale price of such debt or equity; (vi) the net proceeds from sales of such debt orequity by you; (vii) your knowledge of any confidential information related to WMI at the timeyou purchased or sold such debt or equity; and (viii) any communications you had had aboutWMI, WMB, or such debt or equity at the time you purchased such debt or equity.

2. All documents concerning trade confirmations for buy and sale orders, and copiesof all SEC filings, of the Settlement Noteholders and/or members thereof, including but notlimited to Schedule 13Ds, Schedule 13Fs, and/or forms related to the any change in beneficialownership.

3. All documents concerning your tax or accounting treatment of your ownership of Debtors' debt or equity, including but not limited to any financial statement (audited, unaudited,or otherwise) concerning your ownership of Debtors' debt or equity.

4. All documents concerning any non-public information you possess or havepossessed relating to the Debtors, including but not limited to information that was non-public atthe time it was acquired.

5. All documents relating to the Reorganized Debtor, including but not limited to: allanalyses, valuations, reports and other documents and communications concerning the value of the Reorganized Debtor; all documents and communications relating to the value and possibleuses of the Net Operating Losses carried by the Reorganized Debtor; and all documents andcommunications relating to possible business plans, strategy, potential merger or acquisition, orcredit facilities for the Reorganized Debtor.

6. All minutes regarding meetings of the Settlement Noteholders group.

7. All formal and informal Board or partners meetings, notes, conversations, orcommunications about WMI, WMB, or the purchase or sale of WMB or WMI debt or equitymade or reviewed by the Settlement Noteholders and/or any member thereof.

8. All documents and communications you have had with any third party regardingWMI, WMB, and/or their debt or equity.

9. All documents and communications regarding the Global Settlement Agreement,the settlement of your claims against the Debtors, the negotiations of the Global SettlementAgreement, and/or leading to the Global Settlement Agreement.

10. All documents and communications regarding your document retention policy.

11. All documents and communications regarding your organizational structure.

12. All documents and communications you have had with any brokerage firm aboutWMI, WMB, or their debt or equity.

13. All documents and communications regarding PIERS, including its treatment asdebt or equity, its place in the waterfall structure, and the value of PIERS.

14. All documents and communications regarding any profit you have made oranticipate making as a result of your investment in WMI or WMB debt or equity.

15. All documents and communications related to WMI or WMB since September 1,2008.

16. All documents and communications related to the Worker Homeownership andBusiness Assistance Act of 2009.

17. All documents and communications related to the settlement of any claims held bydebt security holders of WMB, including but not limited to any discussions with Wells Fargo.

18. All documents concerning any internal screening procedure and any otherprocedures you employ to ensure that your trading decisions, including trading decisionsregarding any WMI or WMB debt or equity security, are not informed or affected by anyconfidential information in your possession

19. All documents responsive to any interrogatory in the. Equity Committee's First Setof Interrogatories to the Settlement Noteholders

http://www.kccllc.net/documents/0812229/0812229110118000000000004.pdf