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

Hearing Date: August 3, 2010 Hearing Time: 10:00 a.m.

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

Chapter 7 Case No. 09-15631 (ALG)

TRUSTEES OBJECTION TO MOTION OF CANON FINANCIAL SERVICES, INC. FOR AN ORDER GRANTING RELIEF FROM THE AUTOMATIC STAY PURSUANT TO 11 U.S.C. 362(D)(1)-(2) TO THE HONORABLE ALLAN L. GROPPER, UNITED STATES BANKRUPTCY JUDGE: Yann Geron (the Trustee), as chapter 7 trustee of the estate of Thelen LLP (the Debtor or Thelen), the above-captioned debtor, by his attorneys, Fox Rothschild LLP, as and for his objection to the motion of Canon Financial Services, Inc. (Canon), dated June 2, 2010, for an order granting relief from the automatic stay pursuant to 11 U.S.C. 362(d)(1)-(2) (the Motion), upon information and belief, respectfully sets forth and represents: 1. Canons Motion seeks an order lifting the automatic stay so that it can

recover certain photocopiers which it believed were in the Debtors possession on the petition date. Upon receipt of the Motion, the Trustee contacted counsel to Canon and advised that, at the time of its bankruptcy filing, the Debtor was no longer in possession of its New York office space or the photocopiers which are the subject of the Motion. In light of these facts, the Trustee asserted that the Motion was moot and requested it be withdrawn.

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2.

Counsel to Canon requested additional information relating to the

disposition of the photocopiers. The Trustee contacted Debtors counsel and a member of the dissolution committee and was informed that, to the best of the Debtors recollection, the photocopiers at issue had been left at the Debtors New York office when it was surrendered to the landlord in or about November 2008. This information was relayed to Canons counsel with a renewed request that Canon withdraw the Motion. 3. Canon has not agreed to withdraw the Motion. As a result, the Trustee

was compelled to expend additional estate resources to prepare and file this reply. The Trustee respectfully submits that the Debtors estate was never in possession of the photocopiers which are the subject of Canons motion for relief from the automatic stay. Accordingly, the relief requested cannot be granted and the Motion should be denied. WHEREFORE, the Trustee respectfully requests that that the Motion be denied and that he be granted such other and further relief as is just. Dated: New York, New York July 26, 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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