SETTLEMENT AGREEMENTSettlement Agreement • December 18th, 2009 • New York
Contract Type FiledDecember 18th, 2009 JurisdictionThis Settlement Agreement (“Agreement”), dated as of December 15, 2009 (the “Execution Date”), is made by and among (1) Lehman Brothers Holdings Inc., a Delaware corporation (“LBHI”), (2) Lehman ALI, Inc., a Delaware corporation (“ALI”), (3) Lehman Commercial Paper Inc., a New York corporation (“LCPI”) (LBHI, ALI and LCPI are each referred to herein as a “Lehman Party” and collectively as the “Lehman Parties”), and (4) Dr. Michael C. Frege in his capacity as Insolvency Administrator (Insolvenzverwalter) over the assets of Lehman Brothers Bankhaus Aktiengesellschaft i. Ins. (the “LBB InsAdmin”) (LBHI, ALI, LCPI, and the LBB InsAdmin are each referred to herein as a “Party” and collectively as the “Parties”). Capitalized terms not otherwise defined herein shall have the meanings ascribed to them in Schedule 1 attached hereto and made a part hereof.