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cottonisking

11/16/21 4:19 AM

#96635 RE: cottonisking #96625

The BNYM will make sure that our CTs keep trading as successors' securities.

LBIE is a going concern business.

This bankruptcy has satisfied in full 84% of LBHI's Creditors. LBHI has less than 700 million in remaining cash flow to payout.

Basis for CTs' Plan Trust payout with LBHI's preferred stock:

See docket 59738

"27. The prospectuses upon which Wu purports to have relied clearly provides
that any liability that LBHI would have on the Subordinated Guarantee is subordinated to the level
of preferred equity interests in LBHI:
[LBHI’s] [g]uarantee will constitute unsecured obligations of [LBHI] and will rank
(i) subordinate and junior in right of payment to all other liabilities of [LBHI],
(ii) on a parity with the most senior preferred or preference stock… and (iii) senior
to [LBHI’s] common stock.
[Prospectus IV at 21.]. Thus, if LBHI had any liability on account of the Subordinated Guarantee,
such liability would be subordinate and junior in right of payment to all other liabilities of LBHI
and pari passu with LBHI’s preferred equity, which is not expected to recover from LBHI. Wu
acknowledges this. [Mot. ¶6.]
28. Wu’s cites two lette"

$$$$$

"HEARING DATE AND TIME: June 19, 2019 at 11:00 a.m. (Eastern Time)
WEIL:\97024259\10\58399.0011
WEIL, GOTSHAL & MANGES LLP
767 Fifth Avenue
New York, New York 10153
Telephone: (212) 310-8000
Facsimile: (212) 310-8007
Garrett A. Fail
Attorneys for Lehman Brothers Holdings Inc.
and Certain of Its Affiliates
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
------------------------------------------------------------------x
In re : Chapter 11 Case No.
:
LEHMAN BROTHERS HOLDINGS INC., et al., : 08-13555 (SCC)
:
Debtors. : (Jointly Administered)
------------------------------------------------------------------x
PLAN ADMINISTRATOR’S OBJECTION TO MOTION TO ALLOW LATE CLAIM
TO THE HONORABLE SHELLEY C. CHAPMAN,
UNITED STATES BANKRUPTCY JUDGE:
Lehman Brothers Holdings Inc. (“LBHI”), as Plan Administrator, files this
objection to the Motion for an Order Enforcing the Modified Third Amended Joint Chapter 11
Plan of Lehman Brothers Holdings Inc. and Its Affiliated Debtors for Purposes of Distributions
filed last month by Rex Wu (“Wu”) (ECF No. 59614) (the “Motion”) and respectfully represents:
OBJECTION
1. Wu seeks “approval and granting of [his] Proof of Claim” [Mot. ¶10] – a
claim alleged for the first time in April 2019 as an attachment to his Motion. Specifically, Wu
seeks recovery on a claim of $662,780.77 based on guarantees issued by LBHI (each
a “Subordinated Guarantee”) in connection with securities issued by four separate trusts that
owned subordinated debt issued by LBHI. [Id. at Ex. D.]
08-13555-scc Doc 59738 Filed 05/29/19 Entered 05/29/19 11:47:27 Main Document
Pg 1 of 11"