FOX ROTHSCHILD LLP Yann Geron Nicole N.

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

Hearing Date: October 19, 2011 Hearing Time: 10:00 a.m. Objection Deadline: October 12, 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 APPLICATION FOR AN ORDER AUTHORIZING HIM TO FILE UNDER SEAL SETTLEMENT AGREEMENTS WITH THE DEBTORS FORMER PARTNERS TO COUNSEL TO CITIBANK, N.A., ALL KNOWN CREDITORS AND PARTIES IN INTEREST, ALL PARTIES HAVING FILED NOTICES OF APPEARANCE 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 Section 105(a) of the Bankruptcy Code, authorizing him to file under seal settlement agreements with the Debtors former partners, a hearing will be held on the 19th day of October, 2011 at 10:00 a.m., 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 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: Yann Geron, 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 September 27, 2011 FOX ROTHSCHILD LLP Attorneys for Yann Geron, Chapter 7 Trustee By: /s/ Yann Geron Yann Geron Nicole N. Santucci (Of Counsel) 100 Park Avenue, Suite 1500 New York, New York 10017 (212) 878-7900

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