Lehman Brothers Financial SA (LEHNQ)

[cottonisking]

LBIE

The Joint Administrators disclosed that “[t]he recent
strengthening in the financial position of the Administration now suggests that an outcome close
to 100% recovery is likely in the Low case scenario, whilst in the High case scenario there would
be sufficient funds to settle in full all ordinary ranking (unsubordinated) claims with a significant
surplus available to fund claims by Shareholders and/or other unsecured creditors’ claims for
post-Administration interest.”

*******Docket 40674 ******

7. The need for the disclosure sought by the Motion is well demonstrated by the
information recently disclosed by the LBIE Joint Administrators. The Commitment Letter for
the Proposed Transaction was executed by LBHI on September 30, 2013. See Obj. at ¶ 24. Just
eleven days later, on October 11, 2013, the LBIE Joint Administrators issued the LBIE 10th
Progress Report, which indicated “a number of positive developments in the period resulting in
better than expected asset recoveries and a reduction in claim reserves.” See LBIE 10th Progress
Report, attached hereto as Exhibit A, at 6. The Joint Administrators disclosed that “[t]he recent
strengthening in the financial position of the Administration now suggests that an outcome close
to 100% recovery is likely in the Low case scenario, whilst in the High case scenario there would
be sufficient funds to settle in full all ordinary ranking (unsubordinated) claims with a significant
surplus available to fund claims by Shareholders and/or other unsecured creditors’ claims for
post-Administration interest.” Id. According to the Joint Administrators, the improvement in the