FOX ROTHSCHILD LLP Yann Geron Daniel A.

Schnapp 100 Park Avenue, Suite 1500 New York, New York 10017 (212) 878-7900 Attorneys for Yann Geron, Chapter 7 Trustee

Hearing Date: Hearing Time:

December 14, 2011 10:00 a.m. (Prevailing Eastern Time)

Objection Deadline: December 7, 2011

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 HEARING ON TRUSTEES MOTION FOR AN ORDER, PURSUANT TO 11 U.S.C. 105 AND BANKRUPTCY RULES 7016, 7026 AND 9019(b), ESTABLISHING PROCEDURES IN CONNECTION WITH THE PARTNER ADVERSARY PROCEEDINGS AND THE PARTNER CLAIMS TO ALL KNOWN CREDITORS AND PARTIES IN INTEREST, ALL PARTIES HAVING FILED NOTICES OF APPEARANCE, ALL ADVERSARY PROCEEDING DEFENDANTS AND POTENTIAL DEFENDANTS, AND THE OFFICE OF THE UNITED STATES TRUSTEE: PLEASE TAKE NOTICE that, upon the application (the Application), of Yann Geron (the Trustee), as chapter 7 trustee of the estate of Thelen LLP (the Debtor), the abovecaptioned debtor, seeking an order, pursuant to 11 U.S.C. 105 and Rules 7016, 7026 and 9019(b) of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules), establishing procedures in connection with the partner adversary proceedings commenced by the Trustee and the partner claims asserted in the instant bankruptcy proceeding, a hearing will be held on the 14th day of December, 2011 at 10:00 a.m. (Prevailing Eastern Time), or as soon thereafter as counsel can be heard (the Hearing), before the Honorable Allan L. Gropper, United States Bankruptcy Judge, in courtroom #617, at the United States Bankruptcy Court, One Bowling Green, New York, New York 10004, to consider the relief sought by the Application. PLEASE TAKE FURTHER NOTICE that the Trustee has created an informational website concerning this case, where you may access the Application, 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 . PLEASE TAKE FURTHER NOTICE that the general terms of the streamlined
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procedures proposed to be implemented by the Trustee are as follows: Defendants will not be required to appear at the initial pretrial conference, unless defendant has filed a motion seeking a substantive determination by the Bankruptcy Court in response to the complaint which is returnable on that date. Parties will not be required to conduct preliminary discovery conferences. Initial disclosures shall be made within 45 days of the filing of the defendants answer. All fact discovery should be completed within three months of the initial disclosures. No motions may be made in partner adversary proceedings without the Courts prior approval, which may be sought, on notice, via telephone conference with the Court and both the plaintiff and impacted defendant(s). With respect to the settlement of a partner adversary proceeding or claim in which the total amount sought by the Trustee is less than $75,000, the Trustee proposes to serve notice of presentment of orders approving such settlements pursuant to Local Bankruptcy Rule 9074-1. In the event no written objections are received to the proposed settlement, the Court may sign the order approving the settlement without conducting a formal hearing. With respect to the settlement of a partner adversary proceeding or claim in which the total amount sought by the Trustee is greater than $75,000, the Trustee propose to serve notice of the motion of such settlement pursuant to Bankruptcy Rule 9019. Regardless of whether written objections are received to the proposed settlement, a formal hearing will be conducted. Service of the proposed settlements of the partner adversary proceedings or claims will be limited to those parties who filed notices of appearance, the Office of the United States Trustee, and the settling party or that partys counsel.

PLEASE TAKE FURTHER NOTICE that the foregoing constitutes only a general summary of the proposed procedures, and remain subject to bankruptcy court review and approval, in whole or in part. Parties are encouraged to review the Application in its entirety for the specific terms of the proposed procedures. PLEASE TAKE FURTHER NOTICE that the Application has been filed electronically with the Clerk of the United States Bankruptcy Court for the Southern District of New York, and may be reviewed by all registered users of the Courts website at http://www.nysb.uscourts.gov. Copies of the Application may also be obtained by telephonic or e-mail request to the undersigned attorneys for the Trustee, Attn: Alexis Lucisano, Legal Assistant (Tel: (212) 878-7958; e-mail: alucisano@foxrothschild.com).

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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 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, 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, Attorneys for the Trustee, 100 Park Avenue, Suite 1500, New York, New York 10017, Attn: Daniel A. Schnapp, Esq., and (ii) 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 seven days prior to the Hearing. Dated: New York, New York November 21, 2011 FOX ROTHSCHILD LLP Attorneys for Yann Geron, Chapter 7 Trustee By: /s/ Yann Geron Yann Geron Daniel A. Schnapp 100 Park Avenue, Suite 1500 New York, New York 10017 (212) 878-7900

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