Docket _5514 - Document _1

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 ---------------------------------------------------------------x : : In re: : LEHMAN BROTHERS HOLDINGS INC., et al., : : : Debtors. : ---------------------------------------------------------------x

Chapter 11 Case No. 08-13555 (JMP) (Jointly Administered)

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 New York, New York

Respectfully submitted, /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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