FOX ROTHSCHILD LLP Yann Geron Nicole N.

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

Hearing Date: January 27, 2011 At: 10:00 a.m. Objection Deadline: January 20, 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 AND APPROVING TRUSTEES EMPLOYMENT OF CERTAIN PROFESSIONALS TO ASSIST TRUSTEE IN DISCHARGING DUTIES UNDER 11 U.S.C. 704(a)(11), PAY THOSE PROFESSIONALS FROM THE SUBJECT PENSION PLANS UPON FEE APPLICATION, TERMINATE DEBTORS PENSION PLANS, AND QUASH OR CONDITION CERTAIN DISCOVERY DEMANDS DIRECTED TO THE TRUSTEE AS PLAN FIDUCIARY TO COUNSEL TO THE DEPARTMENT OF LABOR, ALL PARTIES REQUESTING NOTICE, ALL KNOWN PLAN PARTICIPANTS, THE DEBTORS PRINCIPAL SECURED CREDITOR, THE DEBTORS TWENTY LARGEST UNSECURED CREDITORS, AND THE OFFICE OF THE UNITED STATES TRUSTEE: PLEASE TAKE NOTICE that upon the motion, dated January 13, 2011 (the Motion), of Yann Geron (the Trustee), as chapter 7 trustee of the estate of Thelen LLP, the above-captioned debtor, seeking an order (i) authorizing and approving Trustees retention of certain professionals to assist him in terminating the Debtors pension plans, (ii) authorizing and approving the payment of those professionals from the assets of those pension plans, to the extent available, and thereafter from the Debtors estate, upon approval of fee applications by the Bankruptcy Court, (iii) authorizing the Trustee to amend the pension plans to authorize an independent fiduciary to act under such plans, (iv) approving the Trustees termination of the Debtors pension plans as warranted, and (v) quashing or conditioning certain discovery directed to the Trustee in connection with his Bankruptcy Code imposed duties as fiduciary of the Debtors pension plans, a hearing will be held on the 27th day of January, 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

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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 Motion and the accompanying memorandum of law, 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 Motion and the accompanying memorandum of law have 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 Motion and memorandum of law 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). PLEASE TAKE FURTHER NOTICE that objections, if any, to the relief sought in the Motion 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 Nicole N. Santucci, 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 January 13, 2011 FOX ROTHSCHILD LLP Attorneys for Yann Geron, Chapter 7 Trustee

By: /s/ Yann Geron Yann Geron Nicole N. Santucci 100 Park Avenue, Suite 1500 New York, New York 10017 (212) 878-7900

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