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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------------------------------- x : In re : MF GLOBAL HOLDINGS, LTD., et al., : : Debtors. : : : -------------------------------------------------------- x

Case No. 11-15059(MG) Chapter 11 (Jointly Administered)

APPLICATION FOR ORDER APPROVING APPOINTMENT OF CHAPTER 11 TRUSTEE TO: THE HONORABLE MARTIN GLENN, UNITED STATES BANKRUPTCY JUDGE: Tracy Hope Davis, the United States Trustee for Region 2 (the “United States Trustee”), by and through her counsel, hereby respectfully applies to this Court, pursuant to Federal Rule of Bankruptcy Procedure 2007.1, for an Order approving her appointment of Louis J. Freeh as the Chapter 11 Trustee in the above-referenced cases. In support thereof, the United States Trustee respectfully states: 1. On October 31, 2011, MF Global Holdings Ltd. (“Holdings”) and MF Global Finance

USA Inc. (together with Holdings, the “Debtors”), each commenced a voluntary case under Chapter 11 of the Bankruptcy Code. 2. On November 7, 2011, the United States Trustee appointed an Official Committee

of Unsecured Creditors (the “Committee”) pursuant to section 1102(a) of the Bankruptcy Code. 3. On November 21, 2011, the Debtors and the Committee filed the Joint Emergency

Motion for Order Pursuant to 11 U.S.C. § 1104 and Fed. R. Bankr. P. 2007.1 Directing Appointment of Chapter 11 Trustee (the “Trustee Motion”). ECF Docket No. 131.

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4.

By Order dated November 22, 2011, ECF Doc. No. 156, the Court directed that the

United States Trustee appoint a Chapter 11 trustee in these cases (the “Trustee Order”). 5. Contemporaneously herewith, the United States Trustee is filing with the Court a

Notice of Appointment of Chapter 11 Trustee, appointing Louis J. Freeh as the trustee (the “Chapter 11 Trustee”) in this case. 6. Pursuant to 11 U.S.C. § 1104(d), in the course of making her appointment, the

United States Trustee has consulted with the following parties in interest in these cases: (a) (b) (c)
(d)

J. Gregory Milmoe and Kenneth S. Ziman of Skadden, Arps, Slate, Meagher & Flom LLP, proposed Counsel to the Debtors; Martin J. Bienenstock of Dewey & LeBoeuf LLP, proposed Counsel to the Committee Peter Pantaleo of Simpson Thacher & Bartlett LLP, Counsel to JP Morgan Chase Bank N.A. Patricia Schrage of the U.S. Securities Exchange Commission Jeannette Vargas, Chief of the Tax and Bankruptcy Unit of the United States Attorneys Office

(e)

Moreover, at the hearing on the Trustee Motion, a representative of the Office of the United States Trustee also requested on the record that any party in interest who wished to submit a nomination for the appointment had to promptly do so. Those nominations were also considered in the course of the United States Trustee’s decision in making her appointment. 7. After consultation with the parties-in-interest who are listed above, the United

States Trustee selected Louis J. Freeh as the Chapter 11 Trustee in these cases. 8. To the best of the United States Trustee's knowledge, Louis J. Freeh has no

connections with the Debtors, their creditors, any other parties-in-interest, their respective attorneys, the United States Trustee, and persons employed in the Office of the United States Trustee, other than those connections set forth on the Declaration of Disinterestedness by Louis

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J. Freeh, a copy of which is annexed hereto as Exhibit 1. WHEREFORE, the United States Trustee requests that the Court enter an Order Approving the Appointment of Louis J. Freeh as the Chapter 11 Trustee, pursuant to 11 U.S.C. §1104(a), a proposed form of which is annexed hereto as Exhibit 2, and for such other and further relief as may seem just and proper in the above-described matter. Dated: New York, New York November 25, 2011 TRACY HOPE DAVIS UNITED STATES TRUSTEE By: /s/ Elisabetta G. Gasparini Elisabetta G. Gasparini Trial Attorney 33 Whitehall Street, 21st Floor New York, New York 10004 Tel. No. (212) 510-0500 Fax. No. (212) 668-2255