FOX ROTHSCHILD LLP Yann Geron Kathleen Aiello 100 Park Avenue, 15th Floor New York, New

York 10017 (212) 878-7900 Counsel to Yann Geron, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------x In re : : THELEN LLP, : : : : Debtor. : ------------------------------------------------------x

Chapter 7

Case No. 09-15631 (ALG)

TRUSTEES APPLICATION, PURSUANT TO 11 U.S.C. 365(d)(1), FOR ORDER (i) EXTENDING TRUSTEES TIME TO ASSUME OR REJECT CERTAIN OF DEBTORS EXECUTORY CONTRACTS AND REJECTING OTHERS TO THE HONORABLE ALLAN L. GROPPER, UNITED STATES BANKRUPTCY JUDGE: Yann Geron (the Trustee), Chapter 7 trustee of the estate of Thelen LLP, the above-captioned debtor (the Debtor or Thelen), by his undersigned counsel, Fox Rothschild LLP, as and for his application (the Application), pursuant to 11 U.S.C. 365(d)(1), for an order extending Trustees time to assume or reject certain of Debtors executory contracts to February 15, 2010, and authorizing Trustee to reject certain other executory contracts, upon information and belief, respectfully sets forth and represents: SUMMARY OF RELIEF REQUESTED 1. At the time of its bankruptcy filing, Thelen was a party to a number of

contracts described as executory in nature. A copy of the Debtors Schedule G, which lists these

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allegedly executory contracts, is attached hereto as Exhibit A. Pursuant to Section 365(d)(1) of the Bankruptcy Code, the Debtors executory contracts for personal property which are determined to be executory in nature will be deemed rejected on November 17, 2009, unless this time is extended by this Court.1 2. By this Application, Trustee seeks a 90-day extension of his time to

assume or reject certain of Debtors executory contracts, to February 15, 2010, without prejudice to further extensions upon further order of this Court. As detailed below, the requested extension is necessary and appropriate in connection with the Trustees efforts to preserve and collect the Debtors accounts receivable, transitioning Debtors off-site client records, and other vital winddown functions which the Trustee will be undertaking. JURISDICTION 3. This Court has jurisdiction over this Application pursuant to 28 U.S.C.

157 and 1334. This is a core proceeding pursuant to 28 U.S.C. 157(b)(2). Venue is proper in this Court pursuant to 28 U.S.C. 1408 and 1409. BACKGROUND 4. On September 18, 2009 (the Petition Date), the Debtor filed a voluntary

petition for relief under chapter 7 of Title 11 of the United States Code (the Bankruptcy Code), in the United States Bankruptcy Court for the Southern District of New York. Yann Geron was appointed interim chapter 7 trustee of the Debtors estate. Mr. Geron has since qualified as permanent chapter 7 trustee and is currently serving in that capacity.
The 60th day following the September 18, 2009 Petition Date is November 17, 2009. Following that period, as may be extended by this Court, unexpired leases and executory contracts will be deemed rejected. Pursuant to Local Bankruptcy Rule 6006-1(b), that time is extended automatically without interim order of this Court to the date the Court enters an order resolving this Application, so long as Trustees application is filed within the initial 60-day window to assume or reject executory contracts and the hearing date on the Trustees application is not more than 14 days following the filing of the application.
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5.

Prior to the Petition Date, Thelen LLP, formerly known as Thelen Reid

Brown Raysman & Steiner, operated largely as a bicoastal law firm with principal offices in New York and San Francisco, and other offices located in 8 U.S. cities, England and China. At its peak, Thelen employed roughly 600 attorneys. Thelen was founded in 1924 in San Francisco as Thelen, Marrin, Johnson & Bridges. In June 1998, Thelen Marrin merged with New York-based Reid & Priest, a firm with approximately 160 attorneys. On December 1, 2006, Thelen Reid & Priest merged with Brown Raysman Millstein Felder & Steiner, LLP, creating the bicoastal structure of the firm. Thelen was ranked 70th in the National Law Journals 2007 survey of the nations largest firms. Upon information and belief, a number of factors caused the firms demise, including difficulties following the Brown Raysman merger, significant partner departures, and failed merger discussions. 6. In October 2008, the Debtor formally voted to dissolve the partnership.

Thereafter, the Debtor began its wind-down process under the guidance of a dissolution committee. Thelens dissolution committee appears to have focused its efforts on collection of Thelens accounts receivable, paying down its secured lines of credit with Citibank N.A., Thelens principal lender, and transitioning client files, using a skeleton staff in a small portion of the Thelens San Francisco offices. After some months in dissolution, it appears that

collections slowed and the Debtors pared-down operating costs became unsustainable under the Debtors arrangement with Citibank. proceeding. 7. Since the filing, the Trustee and Citibank have reached an agreement for As a result, the Debtor filed the instant bankruptcy

the Trustees continued use of Citibanks cash collateral to continue to wind down the Debtors

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affairs and concentrate on collection of receivables.2

Trustee requires additional time to

determine whether it is necessary to maintain certain of the Debtors executory contracts to continue these activities without disrupting the progress already achieved in these efforts. The Trustee is mindful, however, that it is crucial to the estate and its creditors to reduce the financial burden on the estate and to minimize the risk of incurring additional and unnecessary postpetition costs in connection with executory contracts that are not critical and are unlikely provide future value. 8. The Trustee requires additional time to determine whether future

collection and file transfer efforts will require him to assume or reject certain contracts while rejecting other contracts, as specified below. Extension of Time on Records Storage Contracts 9. Debtor appears to have stored more than 250,000 boxes of client records

with at least six storage companies in their facilities throughout the country.3 In the course of the Debtors pre-petition wind-down, the Debtor made significant efforts to coordinate the transfer of off-site, or archived, client files to former Thelen attorneys at their respective firms. The Debtor worked closely with several records storage facilities throughout the country to coordinate such efforts, though it appears that some of these efforts may have become bogged down. Trustee is advised that storage fees are owed to each of the facilities at issue, and no such fees have been paid post-petition. 10. It appears that prior to Thelens bankruptcy filing, many attorneys who

were formerly employed by Thelen requested their respective clients files, and agreed to pay

The Trustee will seek this Courts approval of said stipulation by separate application.

Each of the warehouses has been notified of this motion, and will receive notice of the Trustees motion to implement a records turnover protocol.

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certain sums to retrieve those files. The Trustee intends to proceed with efforts to transfer the client files by implementing a Court-approved protocol4 for turning over client files to clients upon the payment of associated storage and transfer costs. As to files which are unclaimed, Trustee is evaluating what obligation Thelens former attorneys may have to their respective clients for storage and return of those client files. At some point, certain files may need to be destroyed in a method which assures client confidences and privacy are not breached. 11. Trustee recognizes that these activities do not result in a direct economic

benefit to this estate, except to the extent that storage facility claims may be paid and reduced. Trustee is evaluating whether certain of the files at issue are related to outstanding Thelen accounts receivable, which may have an impact on the collection of those accounts. 12. Therefore, it is necessary for Trustee to extend his time to assume or reject

any agreements currently in place with records storage facilities so as to afford Trustee time to implement file turnover protocol and to conclude the disposition of these files. Rejection of San Francisco Office Lease (Excluding Server License) 13. The Debtors West Coast office was located at 101 Second Street, San

Francisco, California 94105 (the Premises). Before dissolution, the Debtor occupied multiple floors within that office building, but by the time of the Petition Date, the Debtor had reduced its occupancy to two office suites on the third floor, pursuant to a non-residential lease agreement between the Debtor and Hines 101 Second Street LP (the Landlord or Hines), entered into on June 25, 2009, as amended (the Reduced Office Lease). The Reduced Office Lease term expired on October 31, 2009. The Debtor operated its pared-down wind-down functions from this location.

The Trustee intends to seek this Courts approval for establishing procedures for disposition of client files under separate application.

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14.

During the pre-petition wind-down, the Debtor maintained its network

server in a portion of the premises which Debtor leased from Reed Smith, under a license entered into on June 30, 2009 (the Reed License). 15. The Trustee has vacated and surrendered the Debtors leased space at this

location, and has come to an agreement with Reed Smith for the continuation of the server space license.5 In this way, the Trustee has eliminated significant ongoing monthly costs while

maintaining the full functionality of the Debtors servers to support accounts receivable collections and other similar accounting functions. 16. Therefore, as a salutary matter, by this Application, Trustee confirms his

rejection of the Reduced Office Lease and his extension of his rights to assume or reject the Reed License. Accounts Receivable Contracts 17. Prior to the filing, Debtors wind-down management engaged a number of

professionals to undertake accounts receivable collections on behalf of the Debtor, including collection agencies and law firms. Trustee has negotiated new agreements with certain of those agencies and law firms which he will engage in this case, under new engagement agreements (effective as of the Petition Date). The new agreements ratify, subsume and supersede Debtors pre-petition engagement agreements. agreements by motion. Trustee will seek Court approval of each of these

To the extent that any of the Debtors pre-petition contracts with

accounts receivable professionals are deemed executory, Trustee seeks an extension of his time to assume these contracts so as to ensure those engagements are not disrupted. These

The Trustee will maintain a license for server space, which the Debtor entered into pre-petition with Reed Smith. This will enable collection efforts to proceed uninterrupted via remote access. Pursuant to a letter from the CFO of Reed Smith, the license will remain as is, except for a $500 monthly concession for the phone switch system, which was initially included in the license but which is no longer required by the estate.

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professionals will be engaged under new contracts which will incorporate the pre-petition contracts to the extent necessary to preserve continuity of service. LEGAL BASIS FOR RELIEF SOUGHT 18. By this Application, the Trustee seeks entry of an order, in substantially

the same form as that annexed hereto as Exhibit B, extending the deadline to assume or reject executory contracts of the Debtors estate, as further detailed above (collectively, the Executory Contracts) to February 15, 2010. 19. Section 365(d)(1) of the Bankruptcy Code states, in relevant part, that in a

Chapter 7 case, if the trustee does not assume or reject an executory contract . . . . within 60 days after the order for relief, or within such additional time as the court, for cause, within such 60-day period, fixes, then such contract is deemed rejected. 20. Pursuant to section 365(d)(1), the Debtors executory contracts will be

deemed rejected on November 17, 2009, unless this Court enters an Order granting an extension of this deadline, provided the Trustee makes his application prior to the expiration of the 60-day statutory deadline, as automatically extended pursuant to Local Bankruptcy Rule 6006-1(b) (the Contract Deadline). 21. The contracts at issue, particularly those entered into with the various

storage facilities, involve complex and multi-party issues. At this early stage in the case, considering its size and complexity, the Trustee believes it is prudent not to allow such contracts to be rejected because of the passing of the statutory deadline. 22. Whether to grant an extension is within the discretion of the bankruptcy

court. See South Street Seaport Ltd. v. Burger Boys, Inc. (In re Burger Boys, Inc.), 94 F.3d 755, 761 (2d Cir. 1996). Requests for extensions of the deadline set forth in Section 365(d)(1) do not

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have to be on notice to all parties, and can be general or specific. 5 Collier on Bankruptcy, 365.01[1] (15th ed. 2002), citing Chapman Inv. Assocs. v. American Healthcare Mgmt., Inc. In re American Healthcare Mgmt., Inc.), 900 F.2d 827, 832, 22 C.B.C.2d 1740, 1746 (5th Cir. 1990) (when a statue gives a court discretion to extend the time in which a party is required to act, the court has authority to grant such an extension without affording other parties notice of a hearing); Willamette Waterfront, Ltd. v. Victoria Station, Inc. (In re Victoria Station, Inc.), 875 F.2d 1380, 1386, 21 C.B.C.2d 483, 491 (9th Cir. 1989) (order extending time to assume or reject a lease merely preserves status quo, and like orders pursuant to Rule 6(b), [may be] entered in the routine administration of the court); Bethesda-Union Society of Savannah, Inc. v. Austin (In re Austin), 21 C.B.C.2d 244, 102 B.R. 897 (Bankr. S.D. Ga. 1989); Ranch House of OrangeBrevard, Inc. v. Gluckstein (In re Ranch House of Orange-Brevard, Inc.), 78 B.R. 323 (Bankr. M.D. Fla. 1987). 23. In accordance with Burger Boys and its progeny, Trustee respectfully

submits that the following reasons constitute adequate cause for extending the Contract Deadline with respect to the subject Executory Contracts: The Trustee plans to proceed with collection of accounts receivable and implement procedures to transfer client files to former-Thelen attorneys, which may require continued performance under certain of the Debtors executory contracts Trustee requires additional time to commence the procedures for collecting accounts receivable and transferring client files to former-Thelen attorneys from various storage facilities throughout the country. The Trustee requires more time to determine which of the Debtors executory contracts is critical to continuing these efforts in the most cost-effective manner possible. The Reed Smith server license is necessary Continuing the server license with Reed Smith will enable estate professionals and other professionals the Trustee intends to retain to pursue collection of the Debtors outstanding accounts receivable, to work via remote access. This arrangement has enabled the Trustee to vacate the Debtors Premises, thereby rejecting the Debtors non-residential lease and significantly decreasing the monthly burn rate for the estate.

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Prejudiced to other parties by this extension is limited Trustee recognizes that he has not, and because of cash collateral limitations, cannot pay for storage costs of the files post-petition. However, transfer of those files to the relevant attorneys will result in recovery of funds which will be paid to the warehouses at issue. In any event, the client files cannot be handled or destroyed absent a full, courtapproved, methodology for notifying clients and ensuring that privacy is fully preserved. The extension will merely maintain the status quo while the Trustee implements his file transfer protocol for the benefit of the respective warehouses. 24. For the foregoing reasons, Trustee submits that granting a reasonable

extension of the Contract Deadline to February 15, 2010 is appropriate, without prejudice to further extensions. NOTICE 25. Trustee has provided notice of this Application and the hearing on this

Application to counsel to the United States Trustee, all known counterparties to storage contracts, all parties having filed notices of appearance, and counsel to Citibank, N.A., the Debtors largest secured lender; and additional notice provided to all known creditors. However, to the extent that he has inadvertently missed any party to an executory contract, it should not prevent any order entered by the Court extending the Contract Deadline from applying to the respective contract. In light of the nature of the relief requested, Trustee submits that the proposed notice is appropriate under the circumstances and that no further notice need be given. PRIOR RELIEF REQUESTED 26. or any other Court. WHEREFORE, Trustee respectfully requests that the Court: (i) grant this Application and enter an order in substantially the same form as the proposed order annexed hereto as Exhibit B, extending the Contract Deadline with respect to the Executory Contracts to No previous application for the relief sought herein has been made to this

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February 15, 2010, without prejudice to further extensions upon agreement between the relevant parties or prior application to this Court; and (ii) grant such other and further relief as is just. Dated: New York, New York November 17, 2009 FOX ROTHSCHILD LLP Counsel to Yann Geron, Chapter 7 Trustee

By: /s/ Yann Geron Yann Geron Kathleen Aiello 100 Park Avenue, 15th Floor New York, New York 10017 (212) 878-7900

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B 6G (Official Form 6G) (12/07)

In re Thelen LLP, a California limited liability partnership, Debtor

Case No. (if known)

SCHEDULE G - EXECUTORY CONTRACTS AND UNEXPIRED LEASES

Describe all executory contracts of any nature and all unexpired leases of real or personal property. Include any timeshare interests. State nature of debtor's interest in contract, i.e., "Purchaser," "Agent," etc. State whether debtor is the lessor or lessee of a lease. Provide the names and complete mailing addresses of all other parties to each lease or contract described. If a minor child is a party to one of the leases or contracts, state the child's initials and the name and address of the child's parent or guardian, such as "A.B., a minor child, by John Doe, guardian." Do not disclose the child's name. See, 11 U.S.C. 112 and Fed. R. Bankr. P. I007(m).

Check this box if debtor has no executory contracts or unexpired leases.

NAME AND MAILING ADDRESS, INCLUDING ZIP CODE, OF OTHER PARTIES TO LEASE OR CONTRACT. DESCRIPTION OF CONTRACT OR LEASE AND NATURE OF DEBTOR'S INTEREST. STATE WHETHER LEASE IS FOR NONRESIDENTIAL REAL PROPERTY. STATE CONTRACT NUMBER OF ANY GOVERNMENT CONTRACT.

1-800-Conference P.O. Box 8103 Aurora,IL 60507-8103

Service Contract

Joel Adler Adler Law Firm 101 Montgomery Street, Suite 2050 San Francisco, CA 94104

Services Contract

Aon Consulting P.O. Box 905188 Charlotte, NC 28290-5188

Service Contract

Applied Technology Group, L.L.C. 335 Hi Crest Drive Auburn, WA 9800 I

Services Contract

AT&T - Universal Biller P.O. Box 79112 Phoenix, AZ 85062-9112

Service Contract

AT&T Payment Center Sacramento, CA 95887-0001

Equiptment Lease

PAGE 201

AT& T P.O. Box 78225 Phoenix, AZ 85062-8225

Services Contract

AT&T P. O. Box 9001310 Louisville, KY 40290-1310

Service Contract

AT&T P.O. Box 78152 Phoenix, AZ 85062-8152

Services Contract

AT& TP.O. Box 78045 Phoenix, AZ 85062-8045

Service Contract

AT&T P.O. Box 13134 Newark, NJ 07101-5634

Service Contract

AT&T P.O. Box 5019 Carol Spints, 1L 60197-5019

Service Contract

AT& T P.O. Box 13148 Newark, NJ 07101-5648

Service Contract

AT&T TeleConference Services PO Box 2840 Omaha, NE 68103-2840

Service Contract

-Kathleen A. Berger

Service Contract

PAGE 202

Canon Financial Services, Inc. P. O. Box 4004 Carol Stream, IL 60197-4004

Equiptment Lease

Cision US Inc POBox 98869 Chicago, IL 60693-8869

Services Contract

Citicorp Leasing, Inc. P.O. Box 7247-6028 Philadelphia, PA 19170-6028

Equiptment Lease

Cogent Communications France SAS 77 Boulevard de la Republique 92257 La Garenne Colombes cedex Paris, France

Service Lease

-John Clark Cogent Communications, Inc. POBox 791087 Baltimore, MD 21279-1087 Computer Network Solutions 11 Commercial Street Plainview, NY 11803 Covad Communications Department 33408 P.O. Box 39000 San Francisco, CA 94139-000 I

Service Contract

Service Contract

Service Contract

Service Contract

Dupont Systems Inc. 325 Sandbank Road, Unit B3 Cheshire, CT 06410

Service Contract

PAGE 203

Equitrac Corporation 14921 Collections Center Drive Chicago Cook, IL 60693

Equiptment Lease

First Bank of Highland Park 1835 First Street Highland Park, IL 60035

Equiptment Lease

Ira M. Friedman Friedman & Friedman 9454 Wilshire Boulevard, Suite 313 Beverly Hills, CA 90212

Services Contract

GE Capital P.O. Box 7247-7878 Philadelphia, PA 19170-7878

Equiptment Lease

Hines 101 Second Street LP Dept 33661 POBox 39000 San Francisco, CA 94139

Lease for office space at 101 Second Street, San Francisco, CA

Intemap Network Services Box 200111 Pitsburgh, PA 15251

Service Contract

Iron Mountain Records Management P.O. Box 601002 Los Angeles, CA 90060-1002

Service Contract

David Z. Kaufman Kaufman Law, a Professional Corporatin 11350 Random Hills road Fairfax, VA 22030

Service Contract

Lexis-Nexis P.O. Box 894166 Los Angeles, CA 90189-4166 Microsoft Licensing, GP 1401 Elm St., 5th Floor, Dept. 842467 Dallas, TX 75202

Services Contract

Service Contract

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Millennium Storage & Transfer Corp. 3200 Liberty Avenue North Bergen, NJ 07047

Service Contract

MPC Insurance Company POBox 530 Burlington, Vermont 05402-0530

Insurance Provider

National City Vendor Finance P.O. Box 73843 Cleveland, OH 44193

Equiptment Lease

Nex Systems 235 Frank West Circle Stockton, CA 95206

Service Contract

Onsite Associates 300 Montgomery St., Suite 500 San Francisco, CA 94104

Service Contract

Patterson, Belknap, Webb & Tyler LLP 1133 Avenue of the Americas New York, NY 10036-671 0

Service Contract

Don Pearce, Esq. 1500 Broadway, 21" Floor New York, New York 10036

Service Contract

Pitney Bowes Print Management 11335 NE 122nd Way suite 275 Kirkland, WA 98034

Equiptment Lease

Pitney Bowes Global Financial Services P.O Box 856460 Louisville, KY 40285-6460

Equipment lease

Pitney Bowes, Inc. P.O. Box 856390 Louisville, KY 40285-6390

Equiptment Lease

Platinum Funding Services LLC P.O. Box 70849 Charlotte, NC 28272-0849

Equiptment Lease

PriceWaterHouseCoopers LLP P.O. Box 31001-0068 Pasadena, CA 91110-0068

Service Contract

RainMaker Software, Inc. 100 Dublin Hall 1777 Sentry Park West Blue Bell, PA 19422 Reed Smith LLP Reed Smith Centre 225 Fifth Avenue Pittsburgh, PA 15222 Attn: Chief Operating Officer

Service Contract

Lease of San Francisco Data Center

PAGE 205

Robert Lewis Group, LLC c/o Total Records and Logistics Attn: Michael Fruchter 438 W 51" St. New York, NY 10019

Record storage

Shared Technologies Inc. P.O. Box 4869 Houston, TX 77210-4869

Service Contract

Shartsis Friese LLP I Maritime Plaza, 18th Floor San Francisco, CA 94111 Siemens Communications, Inc P.O. Box 99076 Chicago, IL 60693-9076

Services Contract

Service Contract

Sprint P.O. Box4181 Carol Stream, IL 60197

Service Contract

Structuretone 770 Broadway New York, NY 10003 Thompson Hine LLP 3900 Key Center 127 Public Square Cleveland,OH 44114-1291 T-Mobile P.O. Box 51843 Los Angeles, CA 90051-6143 TSC Document Storage (Storage USA) 30-28 Starr Avenue Long Island City, NY 11101 US Bancorp Office Equipment U.S. Bank Technology Finance P.O. Box 955333 St. Louis, MO 63195-5333 US Bank Equipment Finance, Inc Accounts Receivable US Bank Technology Finance St .Louis, MO 63195-5333 US Bancorp Office Equipment Wells Fargo Equipment Finance NW-8704 P.O. Box 1450 Minneapolis, MN 55485-8704 US Bancorp Office Equipment National City Vendor Finance P.O. Box 73843 Cleveland,OH 44193 Verizon POBox 660720 Dallas, TX 75266-0720

Equiptment Lease

Service Contract

Service Contract

Service Contract

Equipment Lease

Equiptment Lease

Service Contract

Service Contract

Service Contract

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Verizon Wireless P.O. Box 408 Newark, NJ 07101-0408

Service Contract

Verizon PO Box 4833 Trenton, NJ 08650-4833

Service Contract

Verizon PO Box 15026 Albany, NY 12212-5026

Service Contract

Verizon Business P.O. Box 371873 Pittsburgh, PA 15250-7873

Service Contract

Verizon POBox 4648 Trenton, NJ 08650-4648

Service Lease

WebEx Communications Inc. PO Box49216 San Jose, CA 95161-9216 Weithom, Stanley S. Scottsdale Professional Offices 8655 East Via DeVentura Scottsdale, AZ 85258 Wells Fargo Equipment Finance NW-8704 P.O. Box 1450 Minneapolis, MN 55485-8704 West Publishing! West Payment Center P.O. Box 6292 Carol Stream, IL 60197-6292 Xerox Corporation P.O. Box 650361 Dallas, TX 75265-0361

Service Contract

Service Contract

Equiptment Lease

Service Contract

Equiptment Lease

Xerox Corporation PO Box 827598 Philadelphia, PA 19182-7181

Equiptment Lease

XL Specialty Insurance Company 70 Seaview Avenue Stamford, CT 06902-6040 Steven G. Yudin Yudin & Yudin 370 Seventh Avenue, Suite 720 New York, NY 10001

Insurance Provider

Services Agreement

PAGE 207

PAGE 208

******

[Ifcompleted on behalfofa partnership or corporation}

I declare under penalty of perjury that I have read the answers contained in the foregoing Schedules A through G and any attachments thereto and that they are true and correct to the best of my knowledge, information and belief.

Date September/?; 2009

Signature

.g---

Edward R. Tinson,. Chief Financial Officer

Exhibit B UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------x In re : : THELEN LLP, : : : : Debtor. : ------------------------------------------------------x

Chapter 7

Case No. 09-15631 (ALG)

ORDER, PURSUANT TO 11 U.S.C. 365(d)(1), EXTENDING TRUSTEES TIME TO ASSUME OR REJECT CERTAIN OF DEBTORS EXECUTORY CONTRACTS Upon the application dated November 17, 2009 (the Application), of Yann Geron (the Trustee), Chapter 7 trustee of the estate of Thelen LLP, the above-captioned debtor (the Debtor), pursuant to 11 U.S.C. 365(d)(1), for an order extending Trustees time to assume or reject certain of Debtors executory contracts to February 15, 2010, without prejudice to further extensions; and upon the hearing on the Application that took place before this Court on December 1, 2009 (the Hearing); and upon the record of the Hearing which is incorporated herein by reference; and with due consideration having been given to any responses received to the Application; and it appearing from the affidavit of service on file that proper and sufficient notice of the Application and Hearing have been given; after due deliberation and sufficient cause appearing therefore, it is hereby ORDERED, that the Court has determined that good and sufficient notice of the Application and Hearing has been given, and no other or further notice is required; and it is further

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ORDERED, that pursuant to 11 U.S.C. 365(d)(1), the period within which the Trustee may assume or reject the Debtors executory contracts with warehouse for the storage of records and the Reed License (as detailed in the Application) is extended by 90 days, through and including February 15, 2010, without prejudice to any requests for further extensions by the Trustee; and it is further ORDERED, that the extension granted in this Order is without prejudice to any parties rights to request that the Trustees time to assume or reject any executory contract be shortened for cause shown; and it is further ORDERED, that to the extent Trustee wishes to seek an additional extension of his time to assume or reject executory contracts, he is authorized to do so by notice of presentment in the manner provided for by LBR 9074-1, and he is directed to provide such notice of presentment to the Office of the United States Trustee and all parties to the relevant executory contracts. Dated: New York, New York _______________, 2009 HONORABLE ALLAN L. GROPPER UNITED STATES BANKRUPTCY JUDGE

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