Hearing (Interim) Date: March 18, 2011 at 10:00 a.m.

(ET) Objections Due: March 17, 2011 at 6:00 p.m. (ET)

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)

AMENDED NOTICE1 OF DEBTORS EMERGENCY MOTION AND MEMORANDUM OF LAW FOR INTERIM AND FINAL (I) APPROVAL OF POSTPETITION FINANCING, (II) AUTHORITY TO USE CASH COLLATERAL, (III) GRANTING OF CERTAIN LIENS, (IV) GRANTING ADEQUATE PROTECTION, AND (V) MODIFYING AUTOMATIC STAY PLEASE TAKE NOTICE that a hearing on the above referenced motion (the Motion)2 dated March 16, 2011 of Lehr Construction Corp., the debtor and debtor in possession (the Debtor), for an interim order approving postpetition financing and use of cash collateral, and certain related relief, all as more fully set forth in the Motion, shall be held before

This Notice amends the previous notice filed by the Debtor on March 16, 2011 (Docket No. 63) to clarify that any objections to the Motion should be served on the Chambers of Judge Stuart Bernstein, who will be presiding over this hearing on Judge Sean Lanes behalf.
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A copy of the Motion may be obtained on the Debtors website: http://www.omnimgt.com/sblite/lehr

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the Honorable Stuart M. Bernstein, United States Bankruptcy Judge, in Room 723 of the United States Bankruptcy Court for the Southern District of New York (the Bankruptcy Court), One Bowling Green, New York, New York 10004, on March 18, 2011 at 10 a.m. (Prevailing Eastern Time) (the Hearing Date). PLEASE TAKE FURTHER NOTICE that any responses or objections to the Motion must be in writing, shall conform to the Federal Rules of Bankruptcy Procedure and the Local Bankruptcy Rules for the Southern District of New York, and shall be filed with the Bankruptcy Court (a) electronically in accordance with General Order M-399 (which can be found at www.nysb.uscourts.gov) by registered users of the Bankruptcy Courts filing system and (b) by all other parties in interest on a 3.5 inch disk, compact disc, or flash drive, preferably in WordPerfect, or any other Windows-based word processing format (with two hard copies delivered directly to the Chambers of the Honorable Stuart M. Bernstein) and served upon: (i) the Debtor, Lehr Construction Corp., 902 Broadway, New York, New York 10010 (Attn: Frederick Coffey) (Fred.Coffey@lehrcc.com); (ii) attorneys to the Debtor, Cooley LLP, 1114 Avenue of the Americas, New York, New York, 10036 (Attn: James A. Beldner, Esq.) (jbeldner@cooley.com); (iii) the Office of the United States Trustee for the Southern District of New York, 33 Whitehall Street, 21st Floor, New York, New York 10004 (Attn: Susan Golden, Esq.) (susan.golden@usdoj.gov), and (iv) Klestadt & Winters LLP, proposed counsel to the Committee, 570 Seventh Ave., New York, New York 10018 (Attn: Tracy Klestadt, Esq.) (tklestadt@klestadt.com), in each case so as to be received no later than 6:00 p.m. on March 17, 2011 (Prevailing Eastern Time) (the Objection Deadline). PLEASE TAKE FURTHER NOTICE that if no objections are timely filed and served with respect to the Motion, the Debtor may, on or after the Objection Deadline, submit to the

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Bankruptcy Court an order substantially in the form of the proposed order annexed to the Motion, which order may be entered with no further notice or opportunity to be heard. PLEASE TAKE FURTHER NOTICE that a final hearing regarding the requested relief in the Motion shall be set by the Court and notice of such hearing date and objection deadline shall be provided by the Debtor. Dated: March 17, 2011 New York, New York
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 James A. Beldner Lesley A. Kroupa Proposed Attorneys for Debtor and Debtor in Possession

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