PLAN TRUST AGREEMENTPlan Trust Agreement • December 14th, 2011 • Lehman Brothers Holdings Inc • Security brokers, dealers & flotation companies • New York
This Plan Trust Agreement (this “Trust Agreement”), dated and effective as [—], 2011, by and among Lehman Brothers Holdings Inc. (“LBHI”) and the following parties (each, together with any successor thereto, a “Trustee” and collectively, the “Trustees”), (1) Rutger Schimmelpenninck, not in his individual or personal capacity, but solely in his capacity as co-bankruptcy trustee (curatoren) for Lehman Brothers Treasury Co. B.V., (2) Dr. Michael C. Frege, not in his individual or personal capacity, but solely in his capacity as insolvency administrator (Insolvenzverwalter) of Lehman Brothers Bankhaus AG, (3) John Suckow, not in his individual or personal capacity, but solely in his capacity as the President of LBHI and designee of LBHI, (4) Julie Becker of Wilmington Trust, N.A., and Noel P. Purcell of Mizuho Corporate Bank, Ltd., neither in her or his, respectively, individual or personal capacity, but solely in her or his, respectively, capacity as a co-chairperson and member of the Cre
SETTLEMENT AGREEMENTSettlement Agreement • December 14th, 2011 • Lehman Brothers Holdings Inc • Security brokers, dealers & flotation companies • New York
This Settlement Agreement (the “Agreement”) is made and entered into as of November 23, 2011 (the “Execution Date”), by and among Lehman Brothers Holdings Inc. (“LBHI”), Lehman Commercial Paper Inc. (“LCPI,” and together with LBHI, the “Debtors”), Deutsche Bank AG (“Deutsche Bank”), Monarch Alternative Capital LP (“Monarch”), Stone Lion Portfolio L.P. (“Stone Lion”), Permal Stone Lion Fund Ltd. (“Permal”), Centerbridge Credit Advisors LLC (“Centerbridge”), Anchorage Capital Group, L.L.C. (“Anchorage,” and collectively with Monarch, Stone Lion, Permal, and Centerbridge, in each case on behalf of themselves and their managed entities, funds and accounts, as applicable, the “Participants”). The Debtors, Deutsche Bank and the Participants shall each be referred to individually as a “Party” and collectively as the “Parties.”
