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May 18, 2009 - Motion of OCC to Not Disclose All Information to Unsecured Creditors

Despite what is required by section 1102(b)(3)(A) of the Bankruptcy Code, the Committee requests approval not to disseminate to any entity(as defined by Section 101(15) of the Bankruptcy Code, “Entity”), including any creditors that are not members of the Committee (“Non-Committee Creditors”): (i) any non-public information concerning the Debtors or the Committee, including, but not limited to, any confidential, proprietary, or other non-public materials of the Committee and documents, mental impressions, strategy, memoranda, expert reports, legal analysis, interview memoranda or summaries, factual summaries, communications and other information and materials relevant to the Debtors’ bankruptcy cases, whether provided voluntarily or involuntarily by or on behalf of the Debtors or by any third party or prepared by or for the Committee, including any information designated as “Confidential” by the Debtors pursuant to any Confidentiality Agreement; or (ii) any other information if the effect of such disclosure would constitute a general waiver of the attorney-client, work-product, or other applicable privilege possessed by the Debtors or the Committee (whether solely or shared with LA1:#6402842 / D_1752456_1.DOC Page 3 of 5 another party) (separately, the “Confidential Information” or “Privileged Information” or, collectively, the “Confidential/Privileged Information”).

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