JONES DAY

222 East 41st Street

New York, New York 10017
Telephone: (212) 326-3939
Facsimile: (212) 755-7306
Robert W. Gaffey
William J. Hine
Jayant W. Tambe

Attorneys for Debtor

and Debtor in Possession

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK
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:
In re: : Chapter 11
:
LEHMAN BROTHERS HOLDINGS INC., et al., : Case No. 08-13555 (JMP)
:
Debtors. : (Jointly Administered)
:
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NOTICE OF FILING OF UNSEALED

DEBTOR’S RULE 60 MOTION AND RELATED APPENDIXES

PLEASE TAKE NOTICE that on September 15, 2009, Lehman Brothers

Holdings Inc. (the “Debtor”) filed the Debtor’s Motion for an Order, Pursuant to Fed. R. Civ. P.

60 and Fed. R. Bankr. P. 9024, Modifying the September 20, 2008 Sale Order and Granting

Other Relief (Docket No. 5148) (the “Rule 60 Motion”) and five volumes of related appendixes

(Docket Nos. 5149-5151, 5154 and 5156) (the “Appendixes”).

PLEASE TAKE FURTHER NOTICE that, pursuant to the Confidentiality

Stipulation and Protective Order Between the Examiner, Debtors, Trustee, the Official

Committee of Unsecured Creditors of Lehman Brothers Holdings Inc. (the “Committee”) and

Barclays Capital Inc. (Docket No. 4524) (the “Protective Order”), portions of the Rule 60
Motion and Appendixes were filed under seal and, therefore, were electronically filed in redacted

form only.

PLEASE TAKE FURTHER NOTICE that, pursuant to a Stipulation Between

the Debtors, Trustee, Committee and Barclays Capital Inc. Concerning the Discovery Parties’

Unsealing Motions, so-ordered by the Court on October 14, 2009 (Docket No. 5481) (the

“Unsealing Stipulation”), certain information and exhibits contained in the redacted Rule 60

Motion and Appendixes were unsealed, and the Debtor was expressly authorized to file such

documents (to the extent unsealed) in an unredacted form.

PLEASE TAKE FURTHER NOTICE that the Debtor hereby files the Rule 60

Motion and the Appendixes containing the information and exhibits that have been unsealed

pursuant to the Unsealing Stipulation.

Dated: October 15, 2009 Respectfully submitted,

New York, New York

/s/ Robert W. Gaffey

Robert W. Gaffey
Jayant W. Tambe
William J. Hine
JONES DAY
222 East 41st Street
New York, New York 10017
Telephone: (212) 326-3939
Facsimile: (212) 755-7306

ATTORNEYS FOR DEBTOR AND DEBTOR

IN POSSESSION

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