NSM Litigation Chart

Richard, I have obtained a copy of the complaints in all of the NSM
litigation around the country.? Attached is an updated chart identifying all
of the plaintiffs.? I will review the complaints and the applicable statutes
of limitation.

On a related matter, this morning Judge Berle granted defendants leave to
file cross complaints against Schultes and the individual fund managers for
Oaktree and Farallon.? Plaintiffs' counsel argued that the complaints did not
state a cause of action against the fund managers and were duplicative of the
affirmative defenses already stated.? Judge Berle invited Plaintiffs to
pursue any such challenge by demurrer (motion to dismiss).

<<3_BQD01!.DOC<<

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