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THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

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In re:

Chapter 11 Case No. 08-12229 (MFW) (Jointly Administered) Debtors.

WASHINGTON MUTUAL, INC., et aL, 1

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MICHAEL WILLINGHAM and ESOPUS CREEK VALUE LP, Plaintiffs, v. WASHINGTON MUTUAL, INC., Defendant Adversary Proc. No. 10-51297 (MFW)

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NOTICE OF AGENDA OF MATTERS SCHEDULED FOR HEARING ON FEBRUARY 16,2012 AT 9:30A.M. (EST) I. CONTINUED AND/OR RESOLVED MATTERS:

1.

Motion of Debtors Pursuant to Sections 105 and 363 of the Bankruptcy Code for Order Approving Procedures for the Sale of Certain Intellectual Property [Docket No. 1701; filed 10/7/09] Objection Deadline: October 21,2009 at 4:00p.m. (EDT) Objections/Responses Received: A. Objection of JPMorgan Chase Bank, N.A. to the Motion of Debtors Pursuant to Sections 105 and 363 of the Bankruptcy Code for Order Approving Procedures for the Sale of Certain Intellectual Property [Docket No. 1746; filed 10/21/09]

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The Debtors in these chapter II cases along with the last four digits of each Debtor's federal tax identification number are: (i) Washington Mutual, Inc. (3725); and (ii) WMl Investment Corp. (5395). The Debtors' principal offices are located at 1201 Third Avenue, Suite 3000, Seattle, Washington 98101.

RLFI 5812382v. 1

Related Documents: None. Status: The hearing on this matter is continued to a date to be determined. 2. Debtor's Twenty-Third Omnibus (Substantive) Objection to Claims (Claim Nos. 2463,2470, 2500, and 2505) [Docket No. 2443; filed 3/1/10] Objection Deadline: March 15, 2010 at 4:00p.m. (EDT) Objections/Responses Received: A. Response of Denise Cassese, George Rush, Richard Schroer and Whalen & Tusa, P.C., Individually and as Representatives for the Certified Class, to Debtors' Twenty-Third Omnibus (Substantive) Objection to Claims (Claim Nos. 2463,2470,2500, and 2505) [Docket No. 3051; filed 4/5/10] (Amended) Response of Denise Cassese, George Rush, Richard Schroer and Whalen & Tusa, P.C., Individually and as Representatives for the Certified Class, to Debtors' Twenty-Third Omnibus (Substantive) Objection to Claims (Claim Nos. 2463, 2470, 2500, and 2505) [Docket No. 3060; filed 4/6/1 0]

B.

Related Documents:
1.

Notice of Submission of Copies of Proofs of Claim Relating to Debtors' Twenty-Third Omnibus (Substantive) Objection to Claims [Docket No. 3079; filed 4/7/1 0]

Status: The hearing on this matter is adjourned pending final approval by the District Court for the Eastern District of New York of a proposed compromise and settlement. The individual status of each remaining claim subject to this matter is listed on the attached Exhibit A. 3. Debtors' Objection to Proof of Claim Filed by AT&T Corp. (Claim No. 3725) [Docket No. 3691; filed 5/10/10] Objection Deadline: May 17,2010 at 4:00p.m. (EDT); extended to June 28, 2010

Objections/Responses Received:
A.

AT&T Corp.'s Opposition to Debtors' Objection to Proof of Claim Filed by AT&T Corp. (Claim No. 3725) [Docket No. 5268; filed 8/11110] Declaration ofKari La Fleur in Support of Debtors' Objection to Proof of Claim Filed by AT&T Corp. (Claim No. 3725) [Docket No. 5269; filed 8/1111 0]
2

B.

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Related Documents:
1.

Order Directing the Docketing Clerk to Remove Exhibits A and B to the Debtors' Objection to Proof of Claim Filed by AT&T Corp. (Claim No. 3725) from the Docket [Docket No. 3738; filed 5/14/10] AT&T's Motion for Relief Under Confidentiality Order and Related Relief [Docket No. 4345; filed 5/26/10] Order to Shorten Time and Limit Notice of AT&T's Motion for Relief Under Confidentiality Order and Related Relief [Docket No. 4351; filed 5/27/10] Order to Shorten Time and Limit Notice of AT&T's Motion for an Order Authorizing AT&T to File Under Seal a Motion for Relief Under Confidentiality Order and Related Relief [Docket No. 4352; filed 5/27/10] Notice of Hearing Regarding AT&T's Motion for Relief Under Confidentiality Order and Related Relief [Docket No. 4385; filed 5/27/10] Notice of Hearing Regarding AT&T's Motion for an Order Authorizing AT&T to File Under Seal a Motion or Relief Under Confidentiality for Order and Related Relief [Docket No. 4390; filed 5/27/10] Order Approving AT&T's Motion for Relief Under Confidentiality Order and Related Relief [Docket No. 4416; filed 5/28/10] Order Authorizing AT&T to File Under Seal a Motion for Relief Under Confidentiality Order and Related Relief [Docket No. 4417; filed 5/28/1 0] Notice of Submission of Copy of Proof of Claim Relating to Debtors' Objection to Proof of Claim Filed by AT&T Corp. (Claim No. 3725) [Docket No. 4620; filed 6/4/10]

11.

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Status: The hearing on this matter is continued to a date to be determined. 4. Debtors' Forty-Third Omnibus (Substantive) Objection to Claims [Docket No. 4749; filed 6/16/10] Objection Deadline: July 6, 2010 at 4:00p.m. (EDT) Objections/Responses Received: A. B. Objection to Debtors Forty Third Omnibus (Substantive) Objection to Claims Filed by Thomas E. Menake [Docket No. 4814; filed 6/28/1 0] Objection to Debtors Forty Third Omnibus (Substantive) Objection to Claims Filed by Thomas E. Menake [Docket No. 4815; filed 6/28/10]
3
RLFI 5812382v. 1

C.

Response of Yaw M. Mensah, Dime LTW Claimant #95, to Notice of Debtors' Forty-Third Omnibus (Substantive) Objection to Claims [Docket No. 4842; filed 6/29/1 OJ Response to Debtors' Forty-Third Omnibus (Substantive) Objection to Claims Filed by Joseph T. Keirn [Docket No. 4859; filed 7/211 OJ Response to Debtors' Forty-Third and Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by Mary C. McAndrews [Docket No. 4860; filed 7/211 OJ Response to Debtors' Forty-Third and Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by Alan Laties [Docket No. 4861; filed 7/2/1 OJ Response to Debtors' Forty-Third and Forty-Fourth Onmibus (Substantive) Objection to Claims Filed by Alphonso Meo, Jr. [Docket No. 4862; filed 7/2/1 OJ Objection to Debtors Forty Third Onmibus (Substantive) Objection to Claims Filed by Lawrence Grech [Docket No. 4865; filed 7/2/10J Response to Debtors' Forty-Third and Forty-Fourth Omnibus Objections to Claims Filed by Nantahala Capital Partners, LP and Blackwell Capital Partners, LLC [Docket No. 4874; filed 7/6/lOJ Response to Debtor's Forty-Third Omnibus (Substantive) Objection to Claims, as Related to Claim Number 2919 Filed by Brad Christensen [Docket No. 4880; filed 7/6/IOJ Response and Opposition to the Debtors Forty-Third Omnibus (Substantive) Objection to Claims Filed by Edward Mintz [Docket No. 4882; filed 7/611 OJ Response to Debtor's Forty-Third Omnibus (Substantive) Objection to Claims Filed by American National Bank, as Agent [Docket No. 4883; filed 7/6/1 OJ Broadbill Investment Corp's Preliminary Response to Debtors' FortyThird and Forty-Fourth Onmibus Objections to Claims [Docket No. 4892; filed 7/7/1 OJ Objection to the Debtors Forty Third Onmibus (Substantive) Objections to Claims Filed by Joseph & Sheila, Lisa Molloy and as Guardian for Connor Molloy [Docket No. 4894; filed 7/7/1 OJ Response to Debtor's Forty-Third Omnibus (Substantive) Objection to Claims Filed by Douglas A. Rivalsi [Docket No. 4896; filed 7/711 OJ
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D. E.

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P.

Objections to the Debtors Forty-Third Omnibus (Substantive) Objection to Claims Filed by William S. Coverley [Docket No. 4897; filed 7/7/1 OJ Objection to the Debtors Forty Third Omnibus (Substantive) Objection to Claims Filed by Amy Rivers and Ray Rivers [Docket No. 5021; filed 7/14/1 OJ Response to Debtors' Forty-Third and Forty-Fourth Omnibus Objection to Claims Filed by J. Philip Max [Docket No. 5023; filed 7112/IOJ Addendum to My Statement of Opposition to Debtors' Proposed Amended Joint Plan of Reorganization Regarding Claim Nos. 2494 and 3015 Filed by American National Bank [Docket No. 7794; filed 5/20/IIJ

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Related Documents: 1. Notice of Submission of Copies of Proofs of Claim Relating to Debtor's Forty-Third Omnibus (Substantive) Objection to Claims [Docket No. 4877; filed 7/6/IOJ Notice of Adjournment of Hearing on Debtors' Forty-Third and FortyFourth Omnibus (Substantive) Objections to Claims [Docket No. 4910; filed 7/7/1 OJ Notice of Adjournment Sine Die of Hearing on Debtors' Forty-Third and Forty-Fourth Omnibus (Substantive) Objections to Claims [Docket No. 5321; filed 8/20/1 OJ Order Pursuant to Section I 05(A) of the Bankruptcy Code, Bankruptcy Rules 7023 and 9019, and Federal Rule of Civil Procedure 23(E), Approving Stipulation and Agreement Between the Debtors and Class Representatives of the LTW Holders [Docket No. 9649; filed 2/13/12J

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Status: On February 13, 2012, the Court entered an order approving the settlement reached in connection with the Litigation Tracking Warrant litigation. Accordingly, pursuant to the terms of that order, this matter will be resolved upon the later of the effective date of the Seventh Amended Plan or April 16, 2012. The individual status of each claim subject to this matter is listed on the attached Exhibit B. 5. Debtors' Forty-Fourth Omnibus (Substantive) Objection to Claims [Docket No. 4750; filed 6116/IOJ Objection Deadline: July 6, 2010 at 4:00p.m. (EDT)

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RLFl 5812382v. 1

Objections/Responses Received:
A.

Objections to the Notice of Debtors' Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by Gopal D. Surti [Docket No. 4833; filed 7/1/IOJ Objections to the Notice of Debtors' Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by Kanubhai D. Surti [Docket No. 4834; filed 7/1/1 OJ Objections to the Notice of Debtors' Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by Bhupendra D. Surti [Docket No. 4835; filed 7/1/lOJ Response to Debtors' Forty-Third Omnibus (Substantive) Objection to Claims Filed by Joseph T. Kelm [Docket No. 4859; filed 7/2/lOJ Response to Debtors' Forty-Third and Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by Mary C. McAndrews [Docket No. 4860; filed 7/2/1 OJ Response to Debtors' Forty-Third and Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by [Docket No. 4861; filed 7/2/lOJ Response to Debtors' Forty-Third and Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by Alphonso Meo, Jr. [Docket No. 4862; filed 7/2/IOJ Response to Debtors' Forty-Third and Forty-Fourth Omnibus Objections to Claims Filed by Nantahala Capital Partners, LP and Blackwell Capital Partners, LLC [Docket No. 4874; filed 7/6/IOJ Response to Debtors' Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by Eric S. Tower [Docket No. 4887; filed 7/6/lOJ Broadbill Investment Corp's Preliminary Response to Debtors' FortyThird and Forty-Fourth Omnibus Objections to Claims [Docket No. 4892; filed 717/1 OJ Response to Debtor's Forty-Fourth Omnibus (Substantive) Objection to Claims Filed by Greene Associates [Docket No. 4898; filed 717 II OJ Response to Debtors' Forty-Fourth Omnibus (Substance) Objection to Claims Filed by Mark A. Goldstein [Docket No. 4899; filed 7/7/1 OJ Response to Debtors' Forty-Fourth Omnibus (Substance) Objection to Claims Filed by Gerson E. Greene [Docket No. 4900; filed 7/7/IOJ 6

B.

C.

D.

E.

F.

G.

H.

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M.

RLFI 5812382v. I

N.
0.

Response to Debtors' Forty-Fourth Omnibus (Substance) Objection to Claims Filed by Edna H. Greene [Docket No. 4901; filed 7/7/1 0] Response to Debtors' Forty-Fourth Omnibus (Substance) Objection to Claims Filed by Carol A. Martin [Docket No. 4998; filed 7/9/10] Response to Debtors' Forty-Third and Forty-Fourth Omnibus Objection to Claims Filed by J. Philip Max [Docket No. 5023; filed 7/12/10]

P.

Related Documents:
1.

Notice of Submission of Copies of Proofs of Claim Relating to Debtor's Forty-Fourth Omnibus (Substantive) Objection to Claims [Docket No. 4878; filed 7/6/10] Notice of Adjournment of Hearing on Debtors' Forty-Third and FortyFourth Omnibus (Substantive) Objections to Claims [Docket No. 4910; filed 7/711 0] Debtors' Motion for an Order, Pursuant to Bankruptcy Rule 7042 and Section 105(A) of the Bankruptcy Code, (I) Consolidating the Debtors' Forty-Third and Forty-Fourth Omnibus Objections with Adversary Proceeding Commenced by Broadbill Investment Corp., and (II) Staying the Adversary Proceeding [Docket No. 4804; filed 6/24/1 0; Adversary Docket No. 23; filed 6/24/1 0] Notice of Rescheduled Omnibus Hearing Time for July 20, 2010 [Docket No. 4983; filed 7/12110] Notice of Adjourmnent Sine Die of Hearing on Debtors' Forty-Third and Forty-Fourth Omnibus (Substantive) Objections to Claims [Docket No. 5321; filed 8/20110] Order Pursuant to Section 105(A) of the Bankruptcy Code, Bankruptcy Rules 7023 and 9019, and Federal Rule of Civil Procedure 23(E), Approving Stipulation and Agreement Between the Debtors and Class Representatives of the LTW Holders [Docket No. 9649; filed 2/13/12]

11.

111.

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VI.

Status: On February 13, 2012, the Court entered an order approving the settlement reached in connection with the Litigation Tracking Warrant litigation. Accordingly, pursuant to the terms of that order, this matter will be resolved upon the later of the effective date of the Seventh Amended Plan or April 16, 2012. The individual status of each claim subject to this matter is listed on the attached Exhibit C. 6. Debtors' Forty-Sixth Omnibus (Non-Substantive) Objection to Claims [Docket No. 5117; filed 7/21110]

7
RLFl 5812382v. 1

Objection Deadline: August 9, 2010 at 4:00p.m. (EDT); Debtor Response Deadline: December 9, 2010 Objections/Responses Received:
A.

Response to the Notice of Debtors' Forty-Sixth Omnibus (NonSubstantive) Objection to Claims [Docket No. 5232; filed 8/5/1 OJ

Related Documents:
1.

Order Granting Debtors' Forty-Sixth Onmibus Objection to Claims [Docket No. 5324; filed 8/23/10]

(Non-Substantive)

11.

Order Clarifying Order Granting Debtors' Forty-Sixth Onmibus (NonSubstantive) Objection to Claims [Docket No. 5403; filed 9/8/10] Supplemental Submission in Support of Debtors' Forty-Sixth (NonSubstantive) Omnibus Objection with Respect to Claim of Matthew Shore [Docket No. 6290; filed 12/9/10] Second Order Granting Debtors' Forty-Sixth Onmibus (Non-Substantive) Objection to Claims [Docket No. 6526; filed 1/7/11] Order Pursuant to Section 105(A) of the Bankruptcy Code, Bankruptcy Rules 7023 and 9019, and Federal Rule of Civil Procedure 23(E), Approving Stipulation and Agreement Between the Debtors and Class Representatives of the LTW Holders [Docket No. 9649; filed 2/13/12]

111.

lV.

v.

Status: On February 13, 2012, the Court entered an order approving the settlement reached in connection with the Litigation Tracking Warrant litigation. Accordingly, pursuant to the terms of that order, this matter will be resolved upon the later of the effective date of the Seventh Amended Plan or April 16, 2012. The individual status of each remaining claim subject to this matter is listed on the attached Exhibit D. 7. Debtors' Objection to Proof of Claim Filed by the Oregon Department of Revenue (Claim No. 3846) [Docket No. 9113; filed 11129/11] Objection Deadline: December 29, 2011 at 4:00p.m. (EST); Extended to March 15,2012

Objections/Responses Received: None to date. Related Documents:


1.

Debtors' Objection to Proof of Claim filed by the Oregon Department of Revenue (Claim No. 3693) [Docket No. 3196; filed 4/14/10]
8

RLFl 5812382v. 1

11.

Response of the Oregon Department Of Revenue to Debtors' Objection to Proof of Claim No. 3693 [Docket No. 3599; filed 4/29/10] Amended Response of the Oregon Department Of Revenue to Debtors' Objection to Proof of Claim No. 3693 [Docket No. 3600; filed by 4/29/1 OJ Declaration of Curt Brouwer in Support of Motion Debtors' Objection to Proof of Claim Filed by the Oregon Department of Revenue (Claim No. 3846) [Docket No. 9115; filed 11/29/11] Order Granting Debtors' Motion for Leave to Exceed the Page Limit Requirement for Debtors' Objection to Proof of Claim Filed by the Oregon Department of Revenue (Claim No. 3846) [Docket No. 9128; filed 11130/11]

111.

IV.

v.

Status: The hearing on this matter is continued to a date to be determined. 8. Motion for A Protective Order for Claimants AI Brooks, Todd Baker, Deb Horvath, John McMurray, Tom Casey, and David Schneider Pursuant to Rule 26(c) [Docket No. 9294; filed 12/31/11] Objection Deadline: January 12,2012 at 4:00p.m. (EST)

Objections/Responses Received: None to date. Related Documents: None to date. Status: The hearing regarding this matter is continued to a date to be determined. 9. MBS Plaintiffs' Motion for Order Certifying Class for Purposes of the Class Claim Pursuant to Fed. R. Civ. P. 23 and Fed. R. Bankr. P. 7023 and 9014(c) [Docket No. 9462; filed 1120/12] Objection Deadline: February 9, 2012 at 4:00p.m. (EST); Extended to March 7, 2012 at 4:00p.m. (EST)

Objections/Responses Received: None to date. Related Documents:


1.

Brief in Support of Motion for Order Certifying the Class for Purposes of the Class Claim Pursuant to Fed. R. Civ. P. 23 and Fed. R. Bankr. P. 7023 and 9014(c) [Docket No. 9463; filed 1120/12] Debtors' Emergency Motion to Adjourn the Hearing on the MBS Plaintiffs Motion for Order Certifying the Class for Purpose of the Class Claim Pursuant to Federal Rule of Civil Procedure 23 and Bankruptcy Rule 7023 [Docket No. 9624; filed 2/9/12] 9

11.

RLFI 5812382v. I

111.

MBS Plaintiffs' Objection to Debtors' Emergency Motion to Adjourn the Hearing on the MBS Plaintiffs Motion for Order Certifying the Class for Purpose of the Class Claim Pursuant to Federal Rule of Civil Procedure 23 and Bankruptcy Rule 7023 [Docket No. 9630; filed 2/l 0/12] Order Adjourning the Hearing on the MBS Plaintiffs Motion for Order Certifying Class for Purposes of the Class Claim Pursuant to Federal Rule of Civil Procedure 23 and Bankruptcy Rule 7023 [Docket No. 9646; filed 2/13/12]

IV.

Status: The status conference regarding this matter is continued to the onmibus hearing scheduled for March 14,2012 at 10:30 a.m. (EDT). 10. MBS Plaintiffs' Motion to Classify Claim As A Claim 12 Claim [Docket No. 9582; filed 2/7/12] Objection Deadline: March 7, 2012 at 4:00p.m. (EST)

Objections/Responses Received: None to date. Related Documents:


1.

Notice of Motion to Shorten Notice for Motion ofMBS Plaintiffs' Motion to Classify Claim As A Claim 12 Claim [Docket No. 9585; filed 2/7/12] Debtors' Opposition to Motion to Shorten Notice for Motion of MBS Plaintiffs' Motion to Classify Claim As A Claim 12 Claim [Docket No. 9612; filed 2/8/12] MBS' Plaintiffs Reply to Debtors' Opposition to Motion to Shorten Notice for Motion of MBS Plaintiffs' Motion to Classify As A Claim 12 Claim [Docket No. 9618; filed 2/9/12] Joinder of the Official Committee of Unsecured Creditors of Washington Mutual, Inc., et al., to the Debtors' Opposition to Motion to Shorten Notice for Motion of MBS Plaintiffs' Motion to Classify As A Claim 12 Claim [Docket No. 9619; filed 2/9112] Order Denying Motion to Shorten Notice for Motion of MBS Plaintiffs Classify Class Claim As A Class 12 Claim [Docket No. 9647; filed 2/13112]

n.

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v.

Status: The hearing regarding this matter is continued to the omnibus hearing scheduled for March 14, 2012 at 10:30 a.m. (EDT). 11. Michael Willingham Esopus Creek Value, LP v. Washington Mutual, Inc. et al. (Adv. Pro. No. 10-51297)

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RLFI 5812382v. I

A.

The Official Committee of Equity Security Holders' Motion for Summary Judgment, or in the Alternative, for Relief from the Automatic Stay (Adversary Pro. No. 10-50731) [Adversary Docket No. 3; filed 3/111201 OJ

Related Documents: 1. Memorandum of Law of the Official Committee of Equity Security Holders in Support of Its Motion for Summary Judgment, or in the Alternative, for Relief from the Automatic Stay (Adversary Pro. No. 1050731) [Adversary Docket No.4; filed 3/1112010J Black Horse Capital Management LLC's Response in Support of the Equity Committee's Motion for Summary Judgment, or in the Alternative, for Re1ieffrom the Automatic Stay [Docket No. 2738; filed 3/30/20!0J Joinder to the Official Committee of Equity Holders' Motion for Summary Judgment or in the Alternative, for Relief from the Automatic Stay (Adversary Pro. No. 10-50731) [Adversary Docket No. 7; filed 4/7/2010J Opposition of Defendant Washington Mutual, Inc. to Plaintiff's Motion for Summary Judgment, or in the Alternative, for Relief from the Automatic Stay (Adversary Pro. No. 10-50731) [Adversary Docket No.9; filed 4/7/20 I OJ Order Approving Stipulation to Extend Time for Summary Judgment Briefing and Otherwise Responding to Adversary Complaint (Adversary Pro. No. 10-50731) [Adversary Docket No. 10; filed 4/7/2010J Declaration of Brian S. Rosen in Support of Opposition to Motion for Summary Judgment (Adversary Pro. No. 10-50731) [Adversary Docket No. 11; filed 4/7/201 OJ Reply of the Plaintiff Official Committee of Equity Security Holders to Opposition of Defendant Washington Mutual, Inc. to Plaintiffs Motion for Summary Judgment, or in the Alternative, for Relief from the Automatic stay (Adversary Pro. No. 10-50731) [Docket No. 15; filed 4/18/2010J Order Regarding The Official Committee of Equity Security Holders' Motion for Summary Judgment, or In the Alternative, for Relief from the Automatic Stay (Adversary Pro. No. 10-50731) [Adversary Docket No. 20; filed 4/26/2010J Application of the Official Committee of Equity Security Holders for Oral Argument (Adversary Pro. No. 10-50731) [Adversary Docket No. 27; filed 5/2011 OJ

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RLFI 5812382v. 1

x.

Notice of Completion of Briefing (Adversary Pro. No. 10-50731) [Adversary Docket No. 28; filed 5/20/201 0] Defendant Washington Mutual, Inc.'s Response to the Official Committee of Equity Security Holders' Request for Oral Argument (Adversary Pro. No. 10-50731) [Adversary Docket No. 29; filed 6/4/2010] Notice of Entry of Order by United States Bankruptcy Court for the Western District of Washington Transferring Shareholder Action to United States Bankr11ptcy Court for the District of Delaware and Req11est for Hearing (Adversary Pro. No. 10-50731) [Adversary Docket No. 41; filed 6/24/201 0] Defendant Washington Mutual, Inc.'s Response to the Official Committee of Equity Security Holders' Request for Hearing (Adversary Pro. No. 1050731) [Adversary Docket No. 43; filed 7/7/10] Order Granting the Motion of the Official Committee of Equity Security Holders for Order (I) Granting Intervention, and (II) Consolidating Adversary Proceedings (Adv. No. 10-50731) [Adversary Docket No. 58; filed 8/23/10] and (Adv. No. 10-51297) [Adversary Docket No. 13; filed 8/23/10] Plaintiffs Official Committee of Equity Security Holders Statement on Status of the Adversary Proceedings, Request for Hearing on Pending Motions, and Close of Discovery (Adv. No. 10-51297) [Adversary Docket No. 14; filed 9/2/10] Defendant Washington Mutual, Inc.'s Response to the Official Committee of Equity Security Holders' Statement on Status of the Adversary Proceedings, Request for Hearing on Pending Motions, and Close of Discovery (Adv. No. 10-51297) [Adversary Docket No. 16; filed 9/7/1 0] Letter Regarding Allowance of Shareholders Meeting Filed by Emanuel Jason Levy (Adv. No. 10-51297) [Adversary Docket No. 33; filed 10/2911 0] Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Jeff and Trina Estepp (Adv. No. 10-51297) [Adversary Docket No. 34; filed 111111 0] Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Terrance Huff (Adv. No. 1051297) [Adversary Docket No. 35; filed 1111110] Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Jake K. Barrett and Bruce M Barrett (Adv. No. 10-51297) [Adversary Docket No. 36; filed 11/111 0]
12

XL

XII.

XIII.

XIV.

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xv1.

XVII.

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x1x.

xx.

RLFI 5812382v. I

XXI.

Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Gregory R. Byrd (Adv. No. 10-51297) [Adversary Docket No. 37; filed 11/1110J Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by David Shutvet (Adv. No. 1051297) [Adversary Docket No. 38; filed 1113110J Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Raquel Bomacelli (Adv. No. 10-51297) [Adversary Docket No. 39; filed 11/111 OJ Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Mark O'Brien (Adv. No. 1051297) [Adversary Docket No. 40; filed 1111110J Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Dolores Scobey (Adv. No. 1051297) [Adversary Docket No. 41; filed 1111110J Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Jake K. Barrett (Adv. No. 1051297) [Adversary Docket No. 42; filed 1111110J

XXII.

xxm.

xx1v.

xxv.

xxv1.

xxv11. Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Kurt A. Zeller (Adv. No. 1051297) [Adversary Docket No. 43; filed 1111110J xxvm. Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Dominic LoBrutto (Adv. No. 10-51297) [Adversary Docket No. 44; filed 1111110J xx1x. Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Donna A. Woodburn (Adv. No. 10-51297) [Adversary Docket No. 45; filed 1111110J Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Bernd Luers (Adv. No. 1051297) [Adversary Docket No. 46; filed 11/111 OJ Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Michele M. Wright (Adv. No. 10-51297) [Adversary Docket No. 47; filed ll/2/10J

xxx.

xxx1.

xxxn. Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Joseph E. McCluskey (Adv. No. I 0-51297) [Adversary Docket No. 48; filed 11/211 OJ

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xxxiii. Letter in Support of Motion for Sununary Judgment and Request to Schedule a Shareholders' Meeting Filed by Cameron Lapp (Adv. No. 1051297) [Adversary Docket No. 49; filed 11/2/10]
XXXIV.

Letter in Support of Motion for Summary Judgment and Request to Schedule a Shareholders' Meeting Filed by Peter Kirkham (Adv. No. 1051297) [Adversary Docket No. 50; filed 1112/10]

Status: The hearing regarding this matter and the related Motion for Order to Compel Shareholder Meeting originally filed in the Western District of Washington are continued to a date to be determined.

II.

UNCONTESTED MATTER WITH CERTIFICATION OF NO OBJECTION:


12. Motion of Debtors for an Order, Pursuant to Section 105(a) of the Bankruptcy Code and Rule 9019 of the Federal Rules of Bankruptcy Procedure, (I) Approving Settlement Agreement in FDIC Litigation and Authorizing the Debtors' Consununation Thereof and (II) Modifying the Automatic Stay Under Section 362 of the Bankruptcy Code, as Necessary, to Allow Payment of Settlement Amount Under Directors and Officers Insurance Policies [Docket No. 9456; filed 1119/12] Objection Deadline: February 9, 2012 at 4:00p.m. (EST)

Objections/Responses Received: None to date. Related Documents:


1.

Certification of No Objection Regarding Motion of Debtors for an Order, Pursuant to Section 105(a) of the Bankruptcy Code and Rule 9019 of the Federal Rules of Bankruptcy Procedure, (I) Approving Settlement Agreement in FDIC Litigation and Authorizing the Debtors' Consununation Thereof and (II) Modifying the Automatic Stay Under Section 362 of the Bankruptcy Code, as Necessary, to Allow Payment of Settlement Amount Under Directors and Officers Insurance Policies [Docket No. 9651; filed 2/13/12]

Status: On February 13, 2012, the Debtors filed a certification of no objection regarding this matter. Accordingly, no hearing is necessary unless the Court has questions or concerns.

III.

CONTESTED MATTERS GOING FORWARD:


13. Motion to Reconsider Request for an Order to Include in the Record of Case No. 08-12229 (MFW) Pursuant to Section 105(a) of the Bankruptcy Code and Federal Rules of Evidence Previously Filed by William Duke, Pro Se. Docket #9174 and Include an Additional Document [Docket No. 9473; filed 1/23/12] Objection Deadline: January 30, 2012 at 4:00p.m. (EST) 14

RLFI 5812382v. I

Objections/Responses Received: A. Debtors' Response to Motion to Reconsider Request for an Order to Include in the Record of Case No. 08-12229 (MFW), Pursuant to Section 105(a) of the Bankruptcy Code and Federal Rules of Evidence Previously Filed by William Duke, Pro Se Docket #9174 and Include An Additional Document [Docket No. 9516; filed 1/30/12]

Related Documents: None to date. Status: The documents Mr. Duke seeks to include in the record shall be considered in the context of the confirmation hearing. The hearing regarding this matter is going forward. 14. Motion of Debtors for an Order Pursuant to Section 105(a) of the Bankruptcy Code and Bankruptcy Rule 9019 Approving Stipulation and Agreement Between the Debtors and Tranquility Master Fund, Ltd. (A) Resolving Amended Proof of Claim Number 3925 and (B) Allowing Claims for Voting Purposes [Docket No. 9521; filed 1/30/12] Objection Deadline: February 13,2012 at 4:00p.m. (EST)

Objections/Responses Received: A. MBS Plaintiffs' Limited Objection to Motion of the Debtors Approving Stipulation and Agreement Between the Debtors and Tranquility Master Fund, Ltd. [Docket No. 9643; filed 2/13/12]

Related Documents:
1.

Order Shortening the Notice and Objection Periods with Respect to "Motion of Debtors for an Order Pursuant to Section 105(a) of the Bankruptcy Code and Bankruptcy Rule 9019 Approving Stipulation and Agreement Between the Debtors and Tranquility Master Fund, Ltd. (A) Resolving Amended Proof of Claim Number 3925 and (B) Allowing Claims for Voting Purposes" [Docket No. 9524; filed 1/30/12]

Status: A hearing was held on February 1, 2012 solely with respect to the relief requested under Rule 3018. The balance of the motion is going forward. 15. Emergency Motion to Stay Confirmation and Vote Counting, Under the Current Modified Seventh Amended Plan Filed by Farokh Lam [Docket No. 9538; filed 1/31/12] Objection Deadline: February 9, 2012 at 4:00p.m. (EST)

15
RLFI 5812382v. 1

Objections/Responses Received: A. Objection of Debtors to Emergency Motion to Stay Confirmation and Vote Counting, Under the Current Modified Seventh Amended Plan, Filed by Farokh Lam [Docket No. 9628; filed 2/9/12]

Related Documents: None to date. Status: The hearing regarding this matter is going forward. 16. Request for an Order Certifying Confirmation Order for Direct Appeal to the Court of Appeals for the Third Circuit [Docket No. 9559; filed 2/2112] Objection Deadline: February 16, 2012

Objections/Responses Received:
A.

Debtors' Opposition to the TPS Consortium's Anticipatory Request for an Order for Direct Appeal to the Third Circuit [Docket No. 9669; filed 2/14/12]

Related Documents:
1.

Notice of Hearing [Docket No. 9549; filed 2/2112]

Status: The hearing regarding this matter is going forward.

IV.

CONFIRMATION:
17. Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9178; filed 12/12/11] Objection/Response Deadlines: 1. February 7, 2012 at 4:00p.m. (EST)

Objection to Seventh Amended Joint Plan of Affiliated Debtors Filed by Roman Gelsi [Docket No. 9233; filed 12/21/11] Objection of Ganesan Jayaraman to the Debtor's Proposed Seventh Amended Plan of Reorganization Along With Their Disclosure Statement for Contractual Interest Payment of Piers (Junior) Debt Holders to Senior Debt Holders [Docket No. 9269; filed 12/27/11] Supplemental Objection to the Disclosure Statement for the Seventh Amended Plan Filed by Mike Peters [Docket No. 9426; filed 1/17112] Objection and Reservation of Rights by Till Eulenspiegel to the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9458; filed 1/20/12] 16

2.

3.

4.

RLFI 5812382v. 1

5.

Objection to the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code Filed by Mike Peters [Docket No. 9497; filed 1126/12] Response Filed by Radu Metea [Docket No. 9534; filed 1/31112] Emergency Motion to Stay Confirmation and Vote Counting, Under the Current Modified Seventh Amended Plan Filed by Farokh Lam [Docket No. 9538; filed 1/31112] State of Oregon, Department of Revenue's Objection to Seventh Amended Joint Plan of Affiliated Debtors [Docket No. 9557; filed 2/2/12] Objection to the Seventh Amended Joint Plan of Affiliated Debtors by James Berg [Docket No. 9569; filed 2/6/12] Response Filed by Richard C. NAU, MD [Docket No. 9570; filed 2/6/12] Response Filed by Richard Carlson [Docket No. 9571; filed 2/6/12] Objection and Reservation of Rights of Pro Se Shareholders to the Modified Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code as Filed on December 12, 2011 Incorporating the Modification as Filed on January 9, 2012 Filed by Catherine Dziok [Docket No. 9572; filed 2/6112] Letter in Support for Original Request of Physical Share Certificates Filed by Stephen Noftall [Docket No. 9575; filed 2/6/12] Objection of Individual Piers Shareholders to the Seventh Amended Joint Plan of Reorganization and Joinder to Whitebox Objection to Seventh Amended Plan of Reorganization [Docket No. 9576; filed 2/6/12] Franz Kuncic's Objection to the Modified Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code as Filed On December 12, 2011 Incorporating the Modifications as Filed on January 9, 2012 [Docket No. 9577; filed 2/6/12] ACS HR Solutions, LLP f/k/a Excellerate HRO LLP's Limited Objection to the Seventh Amended Joint Plan and Plan Supplement in Support of Seventh Amended Joint Plan of Affiliated Debtors [Docket No. 9579; filed 2/7/12] Limited Objection of Thomas Casey, David Schneider, Todd Baker, Alfred Brooks, Debra Horvath, and John McMurray to the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter II of the United States Bankruptcy Code [Docket No. 9580; filed 2/7/12]

6. 7.

8. 9. 10. 11. 12.

13. 14.

15.

16.

17.

17
RLFI 5812382v. 1

18.

MBS Plaintiffs' Objection to Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code (as may be amended) [Docket No. 9581; filed 2/7/12] ANICO Plaintiffs' Limited Objection to Confirmation of the Seventh Amended Joint Plan of Affiliated Debtors [Docket No. 9583; filed 2/7/12] Limited Objection and Reservation of Rights on Behalf of Voting Classes 16, 19, 22 to Confirmation of the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code Filed by Mariam E. Gorenberg [Docket No. 9587; filed 2/7/12] First Supplement to Objection and Reservation of Rights by Till Eulenspiegel to the Sevent Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9588; filed 2/7/12] Objection of Florin Matache to the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9589; filed 2/7/12] Objection of Willian1 Duke to the Modified Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9590; filed 2/7/12] Objection of Stephen J. Rotella to the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9592; filed 2/7/12] Objection of the TPS Group to Confirmation of the Modified Seventh Amended Plan of Liquidation [Docket No. 9593; filed 2/7/12] Objection of the Consortium of Trust Preferred Security Holders to Confirmation of Debtors' Plan of Liquidation [Docket No. 9594; filed 2/7/12] Exhibit A toMBS Plaintiffs' Objection to Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code (as may be amended) [Docket No. 9595; filed 2/7/12] Objection of Holdco Advsiors, L.P. to Confirmation of the Modified Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9602; filed 2/8/12] Appendix A and Appendix B to Objection of HoldCo Advisors, L.P. to Confirmation of the Modified Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Court [Docket No. 9604; filed 2/8/12] 18

19.

20.

21.

22.

23.

24.

25.

26.

27.

28.

29.

RLFl 5812382v. 1

30.

Limited Objection to Plan of Reorganization 7 and the Treatment of PIERS Supplemental Filed by Shallum Furbush [Docket No. 9607; filed 2/7/12] Objection Filed by Robert R. Ranke! and Carlo Raulcel [Docket No. 9608; filed 2/8/12] Limited Objection, to and Reservation of Rights of, Gregory G. Camas in Respect of the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9621; filed 2/9/12] Reservation of Rights with Respect to Modified Seventh Amended Joint Plan of Reorganization Filed by Wells Fargo Bank, N.A., in its Capacity as Indenture and Guarantee Trustee [Docket No. 9631; filed 2/10/12]

31. 32.

33.

Related Documents: A. Disclosure Statement for the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9179; filed 12/12/11] Notice of Filing of Proposed Supplement to Equity Committee's Proposed Letter in Support of Confirmation of the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9350; filed 1/6/12] Notice of Filing of Blackline of Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9380; filed 1110/12] Notice of Filing Proposed Revised Communication to Members of Class 19 by Trust Preferred Security Holders [Docket No. 9382; filed 1110/12] Notice of Filing Second Modification of Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9400; filed 1/12/12] Order (I) Approving the Proposed Disclosure Statement and the Form and Manner of the Notice of the Proposed Disclosure Statement Hearing, (II) Establishing Solicitation and Voting Procedures, (III) Scheduling A Confirmation Hearing, and (IV) Establishing Notice and Objection Procedures for Confirmation of the Debtors' Seventh Amended Plan [Docket No. 9414; filed 1113/12] Memorandum Order [Docket No. 9481; filed 1125/12]

B.

C.

D. E.

F.

G.

19
RLFI 5812382v. 1

H.

Plan Supplement in Support of Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter ll of the United States Bankruptcy Code [Docket No. 9488; filed 1125/12] Notice of Filing of Plan Supplement in Support of Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter II of the United States Bankruptcy Code [Docket No. 9489; filed 1/25/12] Order Approving, Pursuant to Bankruptcy Rule 3018, Stipulation and Agreement Among the Debtors and the Federal Deposit Insurance Corporation with Respect to the Allowance of Claim Number 2140 Solely for the Purpose of Voting on the Debtors' Seventh Amended Chapter II Plan [Docket No. 9495; filed 1/26/12] Order Approving, Pursuant to Bankruptcy Rule 3 018, Stipulation and Agreement Among the Debtors and JPMorgan Chase Bank, N.A. with Respect to the Allowance of the JPMC Claims Solely for the Purpose of Voting on the Debtors' Seventh Amended Chapter ll Plan [Docket No. 9496; filed 1126/12] Notice of Filing of Cure Costs Related to Executory Contracts Intended to be Assumed or Assumed and Assigned [Docket No. 9501; filed 1126/12] Order Allowing the Class Claim ofthe MBS Plaintiffs Solely for Purposes of Voting on the Seventh Amended Plan [Docket No. 9547; filed 2/1/12] Order Allowing the Agreed Claims of Tranquility Master Fund, Ltd. Solely for Purposes of Voting on the Seventh Amended Plan [Docket No. 9548; filed 2/1112] Affidavit of Service of Robert Q. Klamser [Docket No. 9550; filed 2/2/12] Affidavit of Service of David M. Sharp [Docket No. 9551; filed 2/2/12] Affidavit of Service of David M. Sharp [Docket No. 9552; filed 2/2/12] Affidavit of Service of Mediant Communications re: Solicitation Packages [Docket No. 9597; filed 2/7/12] Affidavit of Publication of Alice Weber for The New York Times [Docket No. 9625; filed 2/9/12] Affidavit of Publication of Albert Fox for The Wall Street Journal [Docket No. 9626; filed 2/9/12] Affidavit of Publication of Kathy Baldwin for The Seattle Times [Docket No. 9627; filed 2/9/12]

I.

J.

K.

L.

M.

N.

0. P. Q. R.

S.

T.

U.

20
RLFI 5812382v. I

V. W. X. Y. Z.

Affidavit of Carlos I. Lara [Docket No. 9635; filed 2/10/12] Affidavit of Carlos I. Lara [Docket No. 9636; filed 2/1 0/12] Affidavit of Carlos I. Lara [Docket No. 9638; filed 2/10/12] Affidavit of Carlos I. Lara [Docket No. 9639; filed 2/10/12] Certification of Counsel Regarding Stipulation and Agreement Between the Debtors and Tricadia Management LLC with Respect to the Debtors' Seventh Amended Plan [Docket No. 9640; filed 2/12/12] Certification of Counsel Regarding Stipulation and Agreement Resolving Objection of Holdco Advisors, L.P. to the Debtors' Seventh Amended Plan [Docket No. 9641; filed 2/12/12] Affidavit of Broadridge Financial Solutions, Inc. [Docket No. 9620; filed 2/9/12] Notice of Fourth Amendment to Second Amended and Restated Settlement Agreement [Docket No. 9642; filed 2/13/12] Statement of Law Debenture Trust Company of New York in Support of the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter ll of the Bankruptcy Code and in Response to Certain Objections [Docket No. 9654; filed 2/13/12] Notice of Election of Treatment ofPriority Tax Claims [Docket No. 9656; filed 2113/12] Declaration of Michael Willingham in Support of Confirmation of the Seventh Amended Plan of Reorganization [Docket No. 9657; filed 2/13112] Notice of Designation of Debtors' Witness List m Support of Confirmation [Docket No. 9658; filed 2/13/12] Declaration of Jonathan Goulding in Support of Entry of an Order Confirming the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter II of the United States Bankruptcy Code [Docket No. 9659; filed 2/13/12] Submission of JPMorgan Chase Bank. N.A. in Support of Confirmation of the Debtors' Seventh Amended Joint Plan [Docket No. 9660; filed 2/13/12]

AA.

BB. CC. DD.

EE. FF.

GG. HH.

II.

21
RLFl 5812382v. 1

JJ.

Declaration of Robert Q. Klamser with Respect to the Tabulation of Votes On and Elections Pursuant to the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9661; filed 2/13/12] Declaration of David M. Sharp with Respect to the Tabulation of Votes On and Elections Pursuant to the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code with Respect to Securities Voting Classes [Docket No. 9662; filed 2/13/12] Debtors' Omnibus Response to Objections to Confirmation of the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code [Docket No. 9663; filed 2/13/12] Debtors' Pre-Hearing Submissions in Connection with Confirmation [Docket No. 9664; filed 2/13/12] Memorandum of Law in Support of Confirmation of the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bm1kruptcy Code [Docket No. 9665; filed 2113/12] Statement of the Official Committee of Unsecured Creditors of Washington Mutual, Inc., et al., in Support of Confirmation of the Seventh Amended Joint Plan of Affiliated Debtors Pursuant to Chapter 11 of the United States Bankruptcy Code and Response to Certain Objections to Confirmation of the Plan [Docket No. 9666; filed 2/13/12]

KK.

LL.

MM. NN.

00.

Status: The hearing regarding this matter is going forward.

22
RLFl 5812382v. I

Dated: February 14, 2012 Wilmington, Delaware

Respectfully submitted,

Mark D. Collins (No. 2981) Michael J. Merchant (No. 3854) Travis A. McRoberts (No. 5274) RICHARDS, LAYTON & FINGER, P.A. 920 North King Street Wilmington, DE 19801 Telephone: (302) 651-7700 Facsimile: (302) 651-7701 -andBrian S. Rosen, Esq. WElL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, New York 10153 Telephone: (212) 310-8000 Facsimile: (212) 310-8007 Attorneys for the Debtors and Debtors in Possession

RLFI 58 123 82v. I