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(212) 479-6086

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James A. Beldner
jbeldner@cooley.com

March 3, 2011
Via FedEx

The Honorable Judge Sean H. Lane United States Bankruptcy Court- S.D. N.Y. One Bowling Green, Room 708 New York, New York 10004-1408
RE: In re Lehr Construction Corp., Bankr. S.D.N.Y. 11-10723 -Insurance

Dear Judge Lane: Pursuant to the terms of the Interim Order Pursuant to Sections 105(a), 362(d), 363(b) and 503(b) of the Bankruptcy Code and Bankruptcy Rules 4001(d) and 6004(a) (I) Authorizing 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 dated February 23, 2011 (Docket No. 15) (the "Interim Order"), Lehr Construction Corp. (the "Debtor'') is authorized to pay all insurance obligations that:
(i) were due and payable or related to the period prior to the Petition Date, without further order of the Court, and

(ii) are or become due and payable or related to the twenty-one (21) day period after the Petition Date up to an aggregate amount of $75,000. A hearing to authorize the Debtor's payments to its insurance carriers on a final basis is scheduled for March 23, 2011 at 11:00 a.m. (ET) (the "Final Hearing"). Upon further review of the Debtor's insurance obligations as well as discussions with counsel to the Debtor's insurance broker, it has come to our attention that the Debtor will need to make additional payments to its insurance carriers, . above the $75,000 cap set forth in the Interim Order, prior to the Final Hearing. We spoke with the United States Trustee, Susan Golden, regarding this issue. Ms. Golden consented to the Debtor fulfilling its current insurance obligations that are to become due and payable between the date hereof and the Final Hearing. The Debtor estimates that approximately $150,000 will become due and payable related to the Debtor's insurance obligations prior to the Final Hearing.

1114 AVENUE OF THE AMERICAS, NEW YORK, NY 10036 T: (212) 479-6000 F: (212) 479-6275 WWW.COOLEY.COM

1704681 v1/NY

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March 3, 2011 Page Two We would appreciate your consideration of this request and having your clerk advise us of any objections to the Debtor continuing to fulfill its insurance obligations in the ordinary course as described in the Debtor's motion dated February 21, 2011 (Docket No. 5) between now and the Final Hearing. We are available for a chambers conference or a telephonic conference to answer any questions the Court may have related to this issue.

JAB:Iak

Cc:

Susan Golden, Esq., Office of the United States Trustee (via E-mail) Lori Lapin Jones, Esq., Lori Lapin Jones PLLC (via E-mail)

1114 AVENUE OF THE AMERICAS, NEW YORK, NY 10036 T: (212) 479-6000 F: (212) 479-6275 WWW.COOLEY.COM

1704681 v1/NY