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

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

Chapter 7 Case No. 09-15631 (ALG)

OMNIBUS NOTICE OF HEARINGS ON APPLICATIONS BY CHAPTER 7 TRUSTEE FOR ORDERS AUTHORIZING TRUSTEE TO (i) LIMIT NOTICE IN THIS CASE, AND (ii) RETAIN EDELMAN ARTS AS HIS ART APPRAISERS & CONSULTANTS AND TO SELL THE DEBTORS ARTWORK AT AN ON-LINE AUCTION, FREE AND CLEAR OF ALL LIENS, CLAIMS AND ENCUMBRANCES TO COUNSEL TO CITIBANK, N.A., COUNSEL TO THE DEBTOR, ALL KNOWN CREDITORS AND PARTIES IN INTEREST, ALL PERSONS HAVING FILED NOTICES OF APPEARANCE, THE OFFICE OF THE UNITED STATES TRUSTEE, AND ANY OTHER PARTIES ENTITLED TO RECEIVE NOTICE PURSUANT TO BANKRUPTCY RULE 2002: PLEASE TAKE NOTICE that Yann Geron (the Trustee), chapter 7 trustee of the estate of Thelen LLP (the Debtor), the above-captioned debtor, has filed a number of applications for orders granting several prongs of relief related to the Debtors estate and its administration, as further detailed below (collectively, the Applications). This notice describes broadly the relief sought by the Trustee in each of the Applications. As further detailed below, the Applications themselves, and specific notices of hearing associated with each of the Applications, have been made publicly available by the Trustee and should be reviewed by any interested party. PLEASE TAKE FURTHER NOTICE that, as further detailed below, a hearing will be held on February 24, 2010, at 10:00 a.m. (the Hearing Date), or as soon thereafter as counsel may be heard, to consider the relief sought in the Trustees Applications. The hearing will be held before the Honorable Allan L. Gropper, United States Bankruptcy Judge, in his courtroom, #617, at the United States Bankruptcy Court, One Bowling Green, New York, New York 10004.

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PLEASE TAKE FURTHER NOTICE that the Trustee has created an informational website concerning this case, where you may access the Applications and their respective exhibits, 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 Applications and exhibits 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 Applications and exhibits may also be obtained by telephonic or e-mail request to the undersigned counsel for the Trustee, Attn: Melissa Lugo, Legal Assistant (Tel: (212) 878-7910; E-mail: mlugo@foxrothschild.com). Summary of Relief Sought in the Respective Applications 1. Motion to Limit Notice: The Trustee has made an application pursuant to 11 U.S.C. 105(a) and Rule 2002 of the Federal Rules of Bankruptcy Procedure, for an order authorizing limited notice and establishing notice procedures. As detailed in this application, the Trustee proposed to limit future notice in this case to the following parties: (i) the Office of the United States Trustee, (ii) counsel to the Debtor, (iii) counsel to Citibank, N.A., (iv) any party that has filed a proof of claim, and (v) any party that has filed a request for notice pursuant to Bankruptcy Rule 2002. The Trustee will file a master service list with the Court and update the master service list as necessary. 2. Motion to Retain Edelman Arts and Authorizing the Trustee to Sell the Debtors Artwork: The Trustee has made an application, (i) pursuant to 11 U.S.C. 327(a) and 328, seeking authorization to retain Edelman Arts, Inc. as his art appraisers and consultants, and (ii) pursuant to 11 U.S.C. 105(a) and 363, and Rules 2002 and 6004 of the Federal Rules of Bankruptcy Procedure, (a) authorizing the Trustee to sell the Debtors artwork (collectively, the Assets) in as-is and where-is condition, at an online auction sale, to the bidders whom have submitted the highest and best offers, free and clear of all liens, claims and encumbrances, (b) establishing sale procedures and authorizing Trustee to pay auction expenses, and (c) approving form and manner of notice. The auction sale is anticipated to take place in the spring 2010. The Trustee proposes to sell the Assets via an online auction at Artnet.com. The initial auction sale will be a 14-day auction1. Any party who desires additional information regarding the Assets, the auction sale, or who is interested in making an offer to purchase the Assets, should contact the Trustees proposed art consultants at: Edelman Arts, Inc., Attn: Ashley Dillman, 136 East 74th Street, New York, NY 10021, Tel: (212) 472-7770, Fax: (212) 349-0105, Email: adillman@edelmansrts.com. Additionally, interested parties are encourage to visit Artnet.com in advance of the auction sale to obtain relevant information relating to the Assets, the auction sale and bidding procedures.

To the extent that unsold artwork remains after the initial Auction Sale, the Trustee will exercise reasonable business judgment and determine if a subsequent auction is necessary.

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A detailed listing of the Assets, including photographs (if available), will be posted on the Trustees informational website, and can be accessed at http://omnimgt.com/SBLite/ThelenLLP. PLEASE TAKE FURTHER NOTICE that objections, if any, to the relief sought in any of the Applications 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 Windowsbased 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, counsel to 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: Marylou Martin, Esq.; so as to be actually received no later than seven days prior to the Hearing Date. Additional notice of objections to certain Applications may be required, and any party wishing to serve an objection is urged to consult the subject application and the notice of hearing specifically associated with that application. Dated: New York, New York January 27, 2010 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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