COOLEY LLP 1114 Avenue of the Americas New York, New York 10036 Telephone: (212) 479-6000 Facsimile:

(212) 479-6275 Lawrence C. Gottlieb James A. Beldner Lesley A. Kroupa Proposed Attorneys for Debtor and Debtor in Possession UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------- x : In re : : LEHR CONSTRUCTION CORP., : : Debtor. : : : ---------------------------------------------------------------- x

Chapter 11 Case No. 11-10723 (SHL)

NOTICE OF AGENDA OF MATTERS SCHEDULED FOR HEARING ON WEDNESDAY, MARCH 23, 2011 Time and Date of Hearing: Location of Hearing: March 23, 2011 at 11:00 a.m. (prevailing Eastern Time) (the Hearing) Judge Sean H. Lanes Courtroom, Room 621, United States Bankruptcy Court for the Southern District of New York, Alexander Hamilton Custom House, One Bowling Green, New York, New York 10004 A copy of each of the pleadings may be viewed on the Courts website at www.ecf.nysb.uscourts.gov and on the Debtors website: http://www.omnimgt.com/sblite/lehr

Copies of Motions:

I.

UNCONTESTED MATTERS 1. Initial Case Conference (Docket No. 17) Status: This matter is going forward. 2. Motion for an Order, Pursuant to Sections 105(a) and 331 of the Bankruptcy Code and Bankruptcy Rule 2016(a), Establishing Procedures for Interim and Monthly Compensation and Reimbursement of Expenses of Professionals (Docket No. 38) Related Documents: None.

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Response Deadline: March 18, 2011 Response(s) Received: No objections were filed. The Debtor received informal comments from the Committee and a revised order will be provided at the hearing. Status: This matter is going forward. 3. Debtors Application for Order Under Bankruptcy Code Sections 327(a) and 328 and Bankruptcy Rules 2014 and 2016 Authorizing Employment and Retention of Cooley LLP as Attorneys for Debtor Nunc Pro Tunc to the Petition Date (Docket No. 39) Related Documents: None. Response Deadline: March 18, 2011 Response(s) Received: None. Status: This matter is going forward. 4. Application of the Debtor for Order Authorizing Retention and Appointment of Omni Management Group as Claims and Noticing Agent for the Clerk of the Bankruptcy Court Under 28 U.S.C. 156(c) Nunc Pro Tunc to February 25, 2011 and Granting Related Relief (Docket No.23) Related Documents: None. Response Deadline: March 18, 2011 Response(s) Received: Omnibus Response filed by the Committee (Docket No. 77). The Debtor will incorporate the comments received by the Committee into the proposed order and will provide a revised order at the hearing. 5. Motion for an Order Pursuant to Sections 105(a) and 366 of the Bankruptcy Code (I) Prohibiting Utilities from Altering, Refusing, or Discontinuing Service, (II) Deeming Utilities Adequately Assured of Future Payment, and (III) Establishing Procedures for Determining Adequate Assurance of Payment (Docket No. 6) Related Documents: Proposed Final Order (Docket No. 27) Response Deadline: March 18, 2011 Response(s) Received: The Debtor received a request for additional adequate assurance from ConEdison, which the Debtor will address pursuant to the procedures set forth in the utilities order once entered by the Court; Omnibus Response filed by the Committee (Docket No. 77). The Debtor will incorporate the comments received by the Committee into the proposed order and will provide a revised order at the Hearing. Status: This matter is going forward.

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II.

CONTESTED MATTERS 6. Motion for an Order, Pursuant to Section 105(a) of the Bankruptcy Code and Bankruptcy Rules 1015(c) and 9007 Implementing Certain Notice and Case Management Procedures (Docket No. 24) Related Documents: None. Response Deadline: March 18, 2011 Response(s) Received: Informal comments received from the Clerk of the Court. A revised order reflecting the Clerks comments will be provided at the Hearing; Omnibus Response filed by the Committee (Docket No. 77) Status: This matter is going forward. 7. Application for Entry of an Order Under Bankruptcy Code Sections 327, 328 and 330 Authorizing Retention and Employment of Rosen Seymour Shapss Martin & Company LLP as Financial Advisor to the Debtor Nunc Pro Tunc to the Petition Date (Docket No. 25) Related Documents: None. Response Deadline: March 18, 2011 Response(s) Received: Limited Objection filed by Capital One, N.A. (Docket No. 75); Omnibus Response filed by the Committee (Docket No. 77) Status: This matter is going forward. 8. Motion for an Order Pursuant to Sections 105(a) and 363(b) of the Bankruptcy Code (I) Authorizing Payment of Wages, Compensation and Employee Benefits and (II) Authorizing Financial Institutions to Honor and Process Checks and Transfers Related to Such Obligations (Docket No. 3) Related Documents: Interim Order (Docket No. 13); Proposed Final Order (Docket No. 30) Response Deadline: March 18, 2011 Response(s) Received: Limited Objection filed by Capital One, N.A. (Docket No. 75); Omnibus Response filed by the Committee (Docket No. 77) Status: This matter is going forward. 9. Motion for an Order Pursuant to Sections 105(a), 362(d), 363(b) and 503(b) of the Bankruptcy Code (I) Authorizing the Debtor to (A) Continue its Workers Compensation Program and its Insurance Programs and (B) Pay All Obligations in Respect Thereof and (II) Authorizing Financial Institutions to Honor and Process Checks and Transfers Related to Such Obligations (Docket No. 5) Related Documents: Interim Order (Docket No. 15); Proposed Final Order (Docket No. 29); Amended Interim Order (Docket No. 50); Omnibus Response filed by the Committee (Docket No. 77) 3

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Response Deadline: March 18, 2011 Response(s) Received: Limited Objection filed by Capital One, N.A. (Docket No. 75) Status: This matter is going forward. 10. Motion Pursuant to Sections 105(a), 363(b), and 541 of the Bankruptcy Code (I) For Authorization to Pay Certain Prepetition Taxes, and (II) to Allow Financial Institutions to Cash and Process Related Checks and Transfers (Docket No. 7) Related Documents: Proposed Final Order (Docket No. 28) Response Deadline: March 18, 2011 Response(s) Received: Limited Objection filed by Capital One, N.A. (Docket No. 75); Omnibus Response filed by the Committee (Docket No. 77) Status: This matter is going forward. 11. Motion for an Order, Pursuant to Sections 105(a), 327, 328, and 330 of the Bankruptcy Code, Authorizing the Employment of Professionals Utilized in the Ordinary Course of Business Nunc Pro Tunc to the Petition Date (Docket No. 31) Related Documents: None. Response Deadline: March 18, 2011 Response(s) Received: Limited Objection filed by Capital One, N.A. (Docket No. 75); Omnibus Response filed by the Committee (Docket No. 77) Status: This matter is going forward. 12. Motion for Relief from Automatic Stay filed by Jerome and Deborah Russo (Docket No. 44) Related Documents: Declaration of Robert K. Erlanger in Support of Motion (Docket No. 45) Response Deadline: March 23, 2011 Response(s) Received: Debtors counsel and counsel to Russo have been in discussions and a revised order will be provided at the Hearing. Status: This matter is going forward. 13. Motion of the Debtor for Entry of an Order Authorizing Payment of Prepetition Critical Construction Vendor Claims and to Provide Adequate Assurance of Future Performance for Subcontractors and Materialmen Who Have Statutory Lien Rights (Docket No. 46) Related Documents: None. Response Deadline: March 18, 2011 4
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Response(s) Received: Limited Objection filed by F&G Mechanical Corporation and Meadowlands Fire Protection (Docket No. 67); Objection filed by Venmar CES, Inc. (Docket No. 74); Limited Objection filed by Capital One, N.A. (Docket No. 75); Omnibus Response filed by the Committee (Docket No. 77) Status: This matter is going forward. 14. Motion to Compel Immediate Payment of Post-Petition Administrative Expense Claims; and Compelling the Debtor to Assume or Reject Executory Contracts, or in the Alternative, Modifying the Automatic Stay to Permit Movants to Terminate the Executory Contracts at their Sole Discretion filed by F&G Mechanical Corporation and Meadowlands Fire Protection (Docket No. 60) Related Documents: Motion to Shorten Time (Docket No. 61); Order Shortening Time (Docket No. 62). Response Deadline: March 21, 2011 Response(s) Received: Limited Objection filed by the Debtor (Docket No. 76) Status: This matter is going forward. III. ADJOURNED MATTERS 15. Motion of Venmar CES, Inc. for Allowance and Immediate Payment of Administrative Expense Claim Pursuant to 11 U.S.C. 503(b)(9) (Docket No. 37) Related Documents: None. Response Deadline: No objection deadline or proposed hearing date was provided by the movant. Response(s) Received: Not applicable. Status: An objection deadline and hearing date will be scheduled at the Hearing. Dated: March 22, 2011 New York, New York Respectfully Submitted,
By: /s/James A. Beldner James A. Beldner

COOLEY LLP 1114 Avenue of the Americas New York, New York 10036 Telephone: (212) 479-6000 Facsimile: (212) 479-6275 Lawrence C. Gottlieb (LG 2565) James A. Beldner (JB 7166) Lesley A. Kroupa (LK 2620) Proposed Attorneys for Debtor and Debtor in Possession

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