zur auffrischung mal um was es heute geht bei der befragung des ec.
messages.finance.yahoo.com/Stocks_(A_to_Z)/...;tof=5&frt=2
Docket #9633 Date Filed: 2/10/2012
PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Federal Rules of Civil
Procedure and Rules 3070 and 9014 of the Federal Rules of Bankruptcy Procedure, the TPS
Group2 and the TPS Consortium3 as parties-in-interest in the above-captioned chapter 11
proceedings, by and through their undersigned attorneys, will take the deposition of a designated
representative of the Official Committee of Equity Security Holders of Washington Mutual, Inc.
(the “Equity Committee”) pursuant to Federal Rule of Civil Procedure 30(b)(6). Federal Rule of
Civil Procedure 30(b)(6) requires the deponent to designate one or more representatives with the
most particularized knowledge as to the matters listed on Schedule A, which shall be interpreted
in accordance with this Notice. The deposition will take place on February 13, 2012, at 1:00
p.m. at the offices of Susman Godfrey LLP, located at 1000 Louisiana, Suite 5100, Houston,
Texas 77002, and will continue from day to day thereafter until complete. The deposition will be
taken before an authorized court reporter or other officer authorized by law to administer oaths
and will be recorded by stenographic means. The deposition will be taken according to the
Federal Rules of Bankruptcy Procedure for the purpose of discovery, use as evidence at any
hearing or trial, or any other purpose allowed by law.
Dated: New York, New York
February 10, 2012
Respectfully submitted,
CAMPBELL & LEVINE LLC
II. TOPICS OF INQUIRY
1. The terms of the Settlement and Plan.
2. The reasonableness of the Settlement.
3. The value of any claims against the Settlement Noteholders, including without
limitation any claims that were, or could have been, asserted in connection with the Standing
Motion.
4. The value of any compromise reflected in the Settlement.
5. The probability of success of litigation of any claims against the Settlement
Noteholders, including without limitation any claims that were, or could have been, asserted in
connection with the Standing Motion.
6. The complexity, expense, and likely duration of litigation of any claims against
the Settlement Noteholders, including without limitation any claims that were, or could have
been, asserted in connection with the Standing Motion.
7. The possible difficulties of collecting on any judgment which might be obtained
from the Settlement Noteholders.
8. The interest of the creditors or other stakeholders in the Settlement.
9. Any factual investigation you conducted concerning any claim against the
Settlement Noteholders.
10. All exhibits or other documents that the Equity Committee intends to offer or rely
upon at the Confirmation Hearing.
11. The selection of members of, and/or professionals for, the Trust Advisory Board,
the Litigation Subcommittee and/or the Reorganized Debtors’ board of directors.
12. The holdings of members of the Equity Committee in common or preferred equity
of Washington Mutual, Inc.
13. The Equity Committee’s supplemental response to frequently asked questions, as
filed on the docket at D.I. 9350.
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