FOX ROTHSCHILD LLP Yann Geron Kathleen Aiello 100 Park Avenue, 15th Floor New York, New

York 10017 (212) 878-7900 Counsel to Yann Geron, Chapter 7 Trustee of the Estate of Thelen LLP

Presentment Date: November 30, 2010 Presentment Time: 12:00 p.m.

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------x In re : : THELEN LLP, : : Debtor. : ------------------------------------------------------x

Chapter 7 Case No. 09-15631 (ALG)

NOTICE OF PRESENTMENT OF TRUSTEES APPLICATION, PURSUANT TO 11 U.S.C. 105(a) AND 363 AND BANKRUPTCY RULES 2002, 6004 AND 9019, FOR APPROVAL OF A STIPULATION BETWEEN THE TRUSTEE AND CLAIMCO, LLC FOR THE SALE OF THE DEBTORS RIGHTS TO A CLASS ACTION SETTLEMENT CLAIM, FREE AND CLEAR OF LIENS, CLAIMS AND ENCUMBRANCES TO COUNSEL TO CITIBANK, CLAIMCO LLC, d/b/a SPECTRUM SETTLEMENT RECOVERY, DEBTORS TOP 20 CREDITORS, ALL PARTIES REQUESTING NOTICE, AND THE OFFICE OF THE UNITED STATES TRUSTEE: PLEASE TAKE NOTICE that upon the application, dated November 16, 2010 (the Application), of Yann Geron (the Trustee), as chapter 7 trustee of the estate of Thelen LLP (the Debtor), the above-captioned debtor, the undersigned will present an order approving the annexed stipulation, dated November 15, 2010 (the Stipulation), pursuant to 11 U.S.C. 105(a) and 363, and Rules 2002, 6004 and 9019 of the Federal Rules of Bankruptcy Procedure, between the Trustee and Claimco, LLC, d/b/a Spectrum Settlement Recovery (Spectrum), which, in general terms provides for the sale of the Debtors rights to a settlement claim in the Microsoft class action lawsuit to Spectrum in the amount of $20,000 (the Microsoft Claim), free and clear of liens, claims and encumbrances, on the 30th day of November, 2010, at 12:00 p.m. (the Presentment Date), to the Honorable Allan L. Gropper, United States Bankruptcy Judge, in chambers, United States Bankruptcy Court for the Southern District of New York (the Court), One Bowling Green, New York, New York 10004. PLEASE TAKE FURTHER NOTICE that the Trustee has created an informational website concerning this case, where you may access the Application and Stipulation, as well as other relevant information concerning this case, including important dates and deadlines. This website may be accessed at http://omnimgt.com/SBLite/ThelenLLP.

NY1 480081v3 11/16/10

PLEASE TAKE FURTHER NOTICE, that any party desiring additional information regarding the Microsoft Claim, or any party interested in making an offer to purchase the Microsoft Claim which is higher or better than Spectrums current offer, should contact the Trustees attorney as follows: Kathleen Aiello, Esq. Fox Rothschild LLP 100 Park Avenue, 15th Floor Tel: (212) 878-7900 Fax: (212) 692-0940 Email: kaiello@foxrothschild.com All offers submitted to Ms. Aiello must adhere to the following: Offer in Writing and Irrevocable: All offers must be submitted in writing and be irrevocable until the entry of an order by the Bankruptcy Court authorizing the Trustee to complete the sale with a bidder who has successfully submitted a higher or better offer (the Successful Bidder)1, and the consummation of such sale. Higher or Better: Any parties desiring to submit a competing bid for the Trustees consideration must offer a cash bid of more than $20,000. Deposit: Submitted contemporaneously with the offer must be a deposit of no less than $10,000, to be held in the Trustees Thelen estate account until entry of the Order by the Bankruptcy Court. Immediately upon entry of the Order, the deposit will be transferred to the Thelen estate and the Successful Bidder must pay the balance of the purchase price within 10 days of the entry of the Order. Deadline for Submitting Offers: All written offers and deposits must be received by the Trustee no later than November 29, 2010 to be considered.

PLEASE TAKE FURTHER NOTICE that objections, if any, to the relief sought in the Application shall be made in writing, filed with the Court electronically in accordance with General Order M-242 by registered users of the Courts electronic case filing system and, by all other parties in interest, mailed to the Clerk of the United States Bankruptcy Court, One Bowling
The Successful Bidder will be required at its sole cost and expense, and with no further involvement from the Trustee or his professionals, to take all necessary measures to access and liquidate the Microsoft Claim.
1

2
NY1 480081v3 11/16/10

Green, New York, New York 10004, on a 3.5 inch floppy disk, preferably in Portable Document Format (PDF), Microsoft Word, WordPerfect, or any other Windows-based word processing format (with a hard copy delivered directly to the Chambers of the Honorable Allan L. Gropper, United States Bankruptcy Judge, United States Bankruptcy Court for the Southern District of New York, One Bowling Green, New York, New York 10004), and served in accordance with General Order M-242 or other form upon: (i) Fox Rothschild LLP, 100 Park Avenue, Suite 1500, New York, New York 10017, Attn: Yann Geron, Esq.; and (ii) The Office of the United States Trustee, 33 Whitehall Street, 21st Floor, New York, New York 10004, Attn: Susan D. Golden, Esq., so as to be actually received no later than one business day prior to the Presentment Date. Unless timely objections are filed, the Order may be entered without a hearing. PLEASE TAKE FURTHER NOTICE that if timely objections are filed and served, or if the Court so directs, a hearing will be held before the Honorable Allan L. Gropper, United States Bankruptcy Judge, at a date to be scheduled by the Court, upon such additional notice as the Court may direct. Dated: New York, New York November 16, 2010 FOX ROTHSCHILD LLP Attorneys for Yann Geron, Chapter 7 Trustee

By: /s/ Yann Geron Yann Geron Kathleen Aiello 100 Park Avenue, Suite 1500 New York, New York 10017 (212) 878-7900

3
NY1 480081v3 11/16/10