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Wednesday, June 15, 2011 11:42:48 PM
http://www.kccllc.net/documents/0812229/0812229110615000000000013.pdf
The Official Committee of Equity Security Holders (“Equity Committee”) of Washington
Mutual Inc. (“WMI” and, together with its chapter 11 debtor-affiliate, WMI Investment Corp.,
the “Debtors”), respectfully submits this motion (the “Motion to Seal”), pursuant to section
107(b) of title 11 of the United States Code, 11 U.S.C. §§ 101-1532 (the “Bankruptcy Code”),
Rule 9018 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule
9018-1(b) of the Local Rules of Bankruptcy Practice and Procedure of the United States
Bankruptcy Court for the District of Delaware (the “Local Rules”), seeking entry of an Order
authorizing it to file under seal its Motion for an Order Compelling Aurelius Capital
Management L.P. to Produce Documents, (the “Motion to Compel”), a copy of which is attached
hereto as Exhibit A [Under Seal]. In support of the Motion to Seal, the Equity Committee
respectfully represents as follows:
1 Debtors
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