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UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: EDISON MISSION ENERGY, et al.,1 Debtors. ) ) Chapter 11 ) ) Case No. 12-49219 (JPC) ) ) (Jointly Administered) )

VERIFIED STATEMENT OF AD HOC COMMITTEE OF SENIOR NOTEHOLDERS OF EDISON MISSION ENERGY PURSUANT TO BANKRUPTCY RULE 2019 Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure, the ad hoc committee of certain holders (the “Senior Noteholder Committee”) of the (i) 7.50% Senior Fixed Rate Notes due 2013 (the “2013 Notes”) and 7.75% Senior Fixed Rate Notes due 2016 (the “2016 Notes”) issued pursuant to that certain Indenture by and between Edison Mission Energy (“EME”) and Wells Fargo Bank, N.A., as trustee (in such capacity, the “Indenture Trustee”), dated as of June 6, 2006 (as amended, modified, waived, or supplemented through the date hereof), and (ii) 7.00% Senior Fixed Rate Notes due 2017 (the “2017 Notes”), 7.20% Senior Fixed Rate Notes due 2019 (the “2019 Notes”), and 7.625% Senior Fixed Rate Notes due 2027 (the “2027 Notes,” and together with the 2013 Notes, 2016 Notes, 2017 Notes, and 2019 Notes, the “Notes”) issued pursuant to that certain Indenture by and between EME and the Indenture Trustee, dated as of May 7, 2007 (as amended, modified, waived, or supplemented through the

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The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, include: Edison Mission Energy (1807); Aguila Energy Company (3425); Camino Energy Company (2601); Edison Mission Energy Fuel Services, LLC (4630); Edison Mission Fuel Resources, Inc. (3014); Edison Mission Fuel Transportation, Inc. (3012); Edison Mission Midwest Holdings Co. (6553); Midwest Finance Corp. (9350); Midwest Generation EME, LLC (1760); Midwest Generation, LLC (8558); Midwest Generation Procurement Services, LLC (2634); Midwest Peaker Holdings, Inc. (5282); Pleasant Valley Energy Company (3233); San Joaquin Energy Company (1346); Southern Sierra Energy Company (6754); and Western Sierra Energy Company (1447). The location of parent Debtor Edison Mission Energy’s corporate headquarters and the Debtors’ service address is: 3 MacArthur Place, Suite 100, Santa Ana, California 92707.

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date hereof), hereby submits this verified statement (the “Verified Statement”) by and through its undersigned counsel and in support thereof states: 1. In May 2012, certain holders of the Notes contacted Ropes & Gray LLP (“Ropes & Gray”) to represent them in connection with a potential restructuring of the above-captioned debtors and debtors-in-possession (collectively, the “Debtors”), resulting in the formation of the Senior Noteholder Committee. In the intervening months before the date of this Verified

Statement, certain additional holders of the Notes joined the Senior Noteholder Committee, and other holders of Notes withdrew from the Senior Noteholder Committee. As of the date of this Verified Statement, Ropes & Gray represents only the Senior Noteholder Committee and does not represent or purport to represent any entities other than the Senior Noteholder Committee in connection with the Debtors’ chapter 11 cases. In addition, the Senior Noteholder Committee does not represent or purport to represent any other entities in connection with the Debtors’ chapter 11 cases. 2. The names and addresses of the members of the Senior Noteholder Committee as of the date hereof are set forth on Exhibit A hereto. The members of the Senior Noteholder Committee hold claims or manage accounts that hold claims against the Debtors arising from the purchase of Notes in the aggregate amount of $2,371,705,000.00. 3. As reported to Ropes & Gray by each member of the Senior Noteholder Committee, as of the date the Debtors filed their chapter 11 cases, the members of the Senior Noteholder Committee held or managed accounts that held in the aggregate the disclosable economic interests set forth on Exhibit B. 4. Nothing contained in this Verified Statement (or Exhibits A or B hereto) should be construed as a limitation upon, or waiver of, any Senior Noteholder Committee member’s rights

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to assert, file and/or amend its claims in accordance with applicable law and any orders entered in these cases. 5. Ropes & Gray reserves the right to amend or supplement this Verified Statement.

Dated: January 16, 2013 Chicago, Illinois /s/ Stephen Moeller-Sally ROPES & GRAY LLP Keith H. Wofford, Esq. (pro hac vice pending) 1211 Avenue of the Americas New York, NY 10036-8704 Telephone: (212) 596-9000 Facsimile: (212) 596-9090 E-mail: keith.wofford@ropesgray.com -ANDROPES & GRAY LLP Stephen Moeller-Sally (pro hac vice) Patricia I. Chen (pro hac vice pending) Matthew F. Burrows (pro hac vice) Prudential Tower 800 Boylston Street Boston, MA 02199-3600 Telephone: (617) 951-7000 Facsimile: (617) 951-7050 E-mail: ssally@ropesgray.com patricia.chen@ropesgray.com matthew.burrows@ropesgray.com -ANDMeghan J. Dolan, Esq. 111 South Wacker Drive, 46th Floor Chicago, IL 60606 Telephone: (312) 845-1200 Facsimile: (312) 845-5500 E-mail: meghan.dolan@ropesgray.com Attorneys for the Senior Noteholder Committee

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EXHIBIT A

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NAME Alden Global Capital Arrowgrass Capital Partners LLP

ADDRESS 885 Third Avenue, 34th Floor New York, NY 10022 1330 Avenue of the Americas 32nd Floor New York, NY 10019 399 Park Avenue, 6th Floor New York, NY 10022 200 Park Avenue New York, NY 10166 280 Park Avenue #5E New York, NY 10017 399 Park Avenue, 16th Floor New York, NY 10022 2000 Avenue of the Stars, 11th Floor Los Angeles, CA 90067 399 Park Avenue, 7th Floor New York, NY 10022 900 3rd Avenue #29 New York, NY 10022 777 Third Ave., Suite 19A New York, NY 10017 8044 Montgomery Road, Suite 555 Cincinnati, OH 45236 1 Station Place Stamford, CT 06902 237 Park Avenue, Suite 900 New York, NY 10017 865 S. Figueroa Street Los Angeles, CA 90017 190 South LaSalle Street Suite 2400 Chicago, IL 60603 2 World Financial Center, Building B 18th Floor New York, NY 10281 9 West 57th Street, 39th Floor New York, NY 10019 1350 Avenue of the Americas, 21st Floor New York, NY 10019 757 Fifth Avenue, #20 New York, NY 10153 1114 Avenue of the Americas 41st Floor

Avenue Capital Group LLC Barclays Capital Inc. BlueMountain Capital Management, LLC Brigade Capital Management, LLC Canyon Capital Advisors, LLC Citi Capital Advisors Claren Road Asset Management, LLC Credit Value Partners, LP Cincinnati High Yield Group of J.P. Morgan Investment Management Inc. Jefferies High Yield Trading, LLC Litespeed Partners, L.P. Metropolitan West Asset Management, LLC Neuberger Berman Fixed Income LLC

Nomura Corporate Research and Asset Management OZ Management LP (on behalf of certain of its investment funds) P. Schoenfeld Asset Management LP Perry Capital River Birch Capital, LLC

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NAME Strategic Value Master Fund, Ltd. Strategic Value Special Situations II, L.P. Strategic Value Special Situations Feeder Fund II-A, Ltd. TCW Asset Management Company TCW Investment Management Company The Distressed Debt Trading Desk of Citigroup Global Markets Inc. Visium Asset Management, L.P.

ADDRESS New York, NY 10036 100 West Putnam Ave. Greenwich, CT 06830 100 West Putnam Ave. Greenwich, CT 06830 100 West Putnam Ave. Greenwich, CT 06830 865 S. Figueroa Street Los Angeles, CA 90017 865 S. Figueroa Street Los Angeles, CA 90017 1615 Brett Road New Castle. DE 19720 888 Seventh Avenue 22nd Floor New York, NY 10019 3033 Excelsior Boulevard Minneapolis, MN 55416 767 Fifth Avenue, 17th Floor New York, NY 10153

Whitebox Advisors, LLC York Capital Management LP

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EXHIBIT B

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NATURE OF DISCLOSABLE ECONOMIC INTEREST 2013 Notes 2016 Notes 2017 Notes 2019 Notes 2027 Notes Midwest Generation, LLC 8.56% Series B Pass-Through Certificates (“PTCs”) Net Long CDS Notes Net Short CDS Notes Short PTCs

AMOUNT $169,041,000.00 $268,598,000.00 $926,548,000.00 $507,581,000.00 $499,937,000.00 $14,100,000.00 $80,028,350.00 $40,800,000.00 $14,094,000.00

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