STIPULATION AND CONSENT ORDER SETTING DEADLINE FOR THE FILING OF OBJECTIONS TO CHAPTER 11 TRUSTEE'S MOTION PURSUANT TO SECTION 506(c)

DUNCAN W. KEIR, Bankruptcy Judge.

WHEREAS, on May 9, 2012, the Court held a status conference (the "Status Conference") in Credit Suisse Securities (USA) LLC, as Collateral Agent v. TMST, Inc., et al., AP No. 09-00574 (DWK) (Bankr. D. Md. Aug. 28, 2009) (the "Adversary Proceeding");

WHEREAS, at the Status Conference, the parties agreed that Joel I. Sher, Chapter 11 Trustee (the "Trustee"), would file a motion pursuant to section 506(c) of 11 U.S.C. §§ 101 et seq. (the "Bankruptcy Code") for any costs and expenses that the Trustee seeks to recover against property determined in the Adversary Proceeding to be the collateral of Credit Suisse Securities (USA) LLC, Credit Suisse International, UBS AG, UBS Securities LLC, Citigroup Global Markets, Ltd., JPMorgan Chase Funding Inc., Bear Stearns Investment Products Inc., Royal Bank of Scotland plc, RBS Securities Inc. (f/k/a Greenwich Capital Markets, Inc.), and Greenwich Capital Derivatives (collectively, the "Counterparties");

WHEREAS, Credit Suisse Securities (USA) LLC initiated and prosecuted the Adversary Proceeding as Collateral Agent on behalf of the Counterparties (the "Collateral Agent"); WHEREAS, on May 21, 2012, the Court entered an Order Setting Deadline for the Trustee to File 506(c) Motion (the "Preliminary Scheduling Order"), [No. 09-17787, D.I. 1578], providing "that if the Trustee files such a motion under Section 506(c), and there is any objection or response thereto, then the opposing parties shall consult and file such report as would be appropriate if the contested matter were an adversary proceeding and therefore Federal Rule [] 26(f) will apply to this matter. Such report shall include a proposed schedule";

WHEREAS, on May 31, 2012, the Trustee filed the Chapter 11 Trustee's Motion Pursuant to Section 506(c) (the "Motion"), [No. 09-17787, D.I. 1583]; and

WHEREAS, the Collateral Agent and the Counterparties have advised the Trustee that they intend to file one or more objections to the Motion and have requested an extension of the deadline for filing objections to the Motion, with all parties reserving all rights, including (but not limited to) any argument as to the standing of any party to file an objection to the Motion;

IT IS HEREBY STIPULATED, AGREED AND ORDERED that

(1) the deadline for the Collateral Agent and the Counterparties to file objections to the Motion shall be July 2, 2012; and

(2) in accordance with the Preliminary Scheduling Order, if any objection(s) to the Motion is/are filed, the Trustee and any objector(s) will consult and file a report in accordance with Rule 26(f) of the Federal Rules of Civil Procedure, including a proposed schedule.

SO ORDERED.