Exhibit 99.1
LBHI |
| Schedule 1 |
Unsecured Claims Summary and Analysis |
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As of March 2010 |
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($ in millions) |
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| Claims |
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| Estimated |
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| Official |
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| Claims |
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| Initial |
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| Register |
| Adj’s (1) |
| Claims |
| Adj’s (2) |
| Analysis |
| Per POR |
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Direct 3rd Party Claims filed against LBHI |
| $ | 170,373 |
| $ | 0 |
| $ | 170,373 |
| $ | 12,176 |
| $ | 182,549 |
| $ | 101,604 | (3) |
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LBHI Intercompany Payables to Affiliates |
| 68,742 |
| 10,592 |
| 79,334 |
| (22,952 | ) | 56,382 |
| 42,966 | (4) | ||||||
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Guarantee Claims filed by 3rd Parties of Affiliates against LBHI |
| 254,976 |
| 0 |
| 254,976 |
| (112,441 | ) | 142,535 |
| 94,138 | (5) | ||||||
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Guarantee Claims filed by Affiliates against LBHI |
| 201,467 |
| 113,123 |
| 314,590 |
| (90,672 | ) | 223,918 |
| 21,186 | (6) | ||||||
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Total |
| $ | 695,558 |
| $ | 123,715 |
| $ | 819,273 |
| $ | (213,889 | ) | $ | 605,384 |
| $ | 259,894 |
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A review of claims both on a substantive basis and for purposes of plan classification is ongoing. Notwithstanding best efforts, given the volume of claims, the documentation supporting those claims and the fact that many claims have been (i) filed in unliquidated amounts, (ii) filed without any supporting documentation, (iii) filed without sufficient documentation and/or (iv) filed without properly identifying the basis for their claim (i.e. claimants asserting either guarantee or or derivative claims but not completing or incorrectly completing the required box on proof of claim form, claimants asserting secured or priority claims with no support for such assertions, etc.), it is likely and expected that claims or portions of claims will be disallowed or reclassified with respect to priority and/or plan class. Such disallowances and reclassifications will affect, and may materially affect, the analysis presented herein.
(1) Upward adjustment to claim amounts that appear to have been incorrectly omitted from the Official Claims Register. The Debtors will work with the Official Claims Agent to update the Official Claims Register as appropriate.
(2) Adjustments to capture certain (i) claims believed to be duplicative of earlier-filed claims or amended by later-filed claims, (ii) upward adjustments to estimate certain liquidated amounts for claims filed without specific liquidated amounts, and (iii) obvious over-statements.
(3) Notwithstanding the requirements in the bar date order, many claims have either been filed without specification of a Debtor or have been filed against what appears to be the incorrect Debtor. To the extent that such claims are later determined to be properly asserted against LBHI or , conversely, that claims asserted against LBHI are determined to be properly asserted against other Debtors, the numbers reflected herein will vary and may vary materially. The amount reflected above is based on the Debtor’s review of 3rd party liaibilities per the LBHI 9-14-08 and 6-30-09 financial statements.
(4) Represents LBHI net intercompany payable as of 9-14-08 except for LB Treasury which was compromised by 50% of the net intercompany payable.
(5) See Schedule 2.
(6) See Schedule 3.
LBHI |
| Schedule 2 |
Classes 7A to 7R |
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Guarantee Claims Filed by 3rd Parties of Affiliates |
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As of March 2010 |
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($ in millions) |
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Class 7 |
| Affiliate |
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7A |
| LBSF |
| $ | 41,552 |
| $ | 15,861 | (1) |
7B |
| LBCS |
| 2,776 |
| 2,776 |
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7C |
| LBCC |
| 353 |
| 353 |
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7D |
| LOTC |
| 310 |
| 310 |
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7E |
| LBDP |
| 702 |
| 201 | (1) | ||
7F |
| LCPI |
| 1,162 |
| 1,162 |
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7G |
| LB International (Europe) |
| 18,203 |
| 18,203 |
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7H |
| Lehman Brothers Limited |
| 4,477 |
| 2,439 | (2) | ||
7I |
| Lehman Brothers Treasury Co. B.V. |
| 28,159 |
| 26,411 | (2) | ||
7J |
| Lehman Brothers Bankhaus AG |
| 37,829 |
| 19,410 | (2) | ||
7K |
| Lehman Brothers Finance S.A. |
| 2,763 |
| 2,763 |
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7L |
| Lehman Brothers Securities NV |
| 746 |
| 746 |
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7M |
| Lehman Brothers Japan Inc. |
| 410 |
| 410 |
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7N |
| Lehman Brothers Holdings Japan Inc. |
| 1,289 |
| 1,289 |
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7O |
| Sunrise Finance Co. |
| 622 |
| 622 |
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7P |
| LB Commercial Corp Asia Ltd |
| 142 |
| 142 |
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7Q |
| LBI |
| 748 |
| 748 |
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7R |
| Schedule 5 (per POR) Affiliates |
| 292 |
| 292 |
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| Total |
| $ | 142,535 |
| $ | 94,138 |
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The claim numbers presented herein relate to the claims estimates provided in Schedule 1 and, as such, the reader should review Schedule 1 and the accompanying notes in conjunction with any review of this Schedule 2.
(1) Based on Debtor’s review of affiliate 3rd party liabilities per the affiliate’s 9-14-08 financial statements and the addition of a 1 times liability provision for estimated ISDA claims over the Affiliate derivative liabilities.
(2) Based on Debtor’s review of affiliate 3rd party liabilities per the affiliate’s 9-14-08 financial statements.
LBHI |
| Schedule 3 |
Class 8 |
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Guarantee Claims Filed by Affiliates |
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As of March 2010 |
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($ in millions) |
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Affiliate |
| Estimated |
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LBSF |
| $ | 8,340 |
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LBCS |
| 1,176 |
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LBCC |
| 1,005 |
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LOTC |
| 52 |
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LCPI |
| 1,004 |
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LB International (Europe) |
| 73,567 |
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Lehman Brothers Europe Limited |
| 1,457 |
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Lehman Brothers Limited |
| 2,071 |
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Lehman Brothers UK Holdings Limited |
| 1,938 |
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LBIE Affiliates (5) |
| 123 |
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Lehman Brothers Treasury Co. B.V. |
| 39 |
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Lehman Brothers Bankhaus AG |
| 24,410 |
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Lehman Brothers Finance S.A. |
| 58,304 |
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Lehman Brothers Securities NV |
| 283 |
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Lehman Brothers Japan Inc. |
| 22,794 |
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Lehman Brothers Holdings Japan Inc. |
| 314 |
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Lehman Brothers Finance (Japan) Inc. |
| 289 |
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Other LBJ affiliates |
| 39 |
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LB Asia Holdings Limited |
| 4,807 |
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LB Commercial Corp Asia Ltd |
| 1,599 |
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LB Securities Asia Limited |
| 1,740 |
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Lehman Brothers Asia Ltd |
| 780 |
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LBAH & LBCCA affiliates (3) |
| 221 |
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LB Finance Asia PTE Ltd |
| 161 |
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LB (Pte) Ltd. |
| 14 |
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Other Singapore affiliates (7) |
| 88 |
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LB (Luxembourg) SA |
| 418 |
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LB Equity Finance (Lux) |
| 103 |
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LBI |
| 11,000 |
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LB RE |
| 1,050 |
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LB Australia |
| 107 |
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Misc. Affiliates |
| 4,624 |
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Total |
| $ | 223,917 |
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Allowed Pursuant to Plan |
| $ | 21,186 |
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The claim numbers presented herein relate to the claims estimates provided in Schedule 1 and, as such, the reader should review Schedule 1 and the accompanying notes in conjunction with any review of this Schedule 3.
(1) Based on Debtor’s preliminary review of guarantee claims filed by affiliates. Includes amounts for claims not picked up by EPIQ summary and adjustments for amended claims, duplicate claims, obvious adjustments, and estimates for certain unliquidated claims. Also, includes estimates for LBSF, LBCS, LBCC, LOTC, LCPI and other affiliates under LBHI’s control not yet required to file proofs of claim.