By Joseph Checkler 
   Of DOW JONES DAILY BANKRUPTCY REVIEW 
 

Barclays Group PLC (BCS) and the Lehman Brothers Holdings Inc.'s (LEHMQ) are continuing their appeals of a judge's split decision last year to the lesser-followed aspects of the so-called "secret-discount lawsuit."

Barclays said the trustee unwinding Lehman Brothers Holdings Inc.'s U.S. brokerage "did not read the nine-page, $50 billion contract" he signed in the days after Barclays bought the brokerage business in 2008. In Friday filings with the U.S. District Court in Manhattan, lawyers for Barclays and the trustee, James W. Giddens, traded their final written arguments ahead of a decision by Judge Katherine B. Forrest, the new judge in the case after Judge Richard J. Holwell retired from the bench last week.

Barclays is asking Forrest to overturn a bankruptcy judge's decision that it should turn over all $2.054 billion in a "margin account" to the trustee. Barclays says much of the money in that account was explicitly designated to go to the British bank as part of the terms of its purchase of Lehman's brokerage.

In the more widely followed portion of a February 2011 ruling, a judge rejected most of the Lehman parent company's claims of Barclays reaping a "secret" windfall when it bought Lehman's broker-dealer unit in September 2008. While Lehman is not appealing that decision, the trustee and Barclays continue to fight over some of the other aspects of the ruling.

The trustee, in renewing its argument that the bankruptcy court was correct to assign the money to the brokerage customers, said in its Friday court filing, "It is odd for an appellee to devote most of its brief to arguing against the trial court's findings, but Barclays cannot otherwise defend the judgment."

The lawyers for Barclays said, "The Trustee's version of history created for this litigation defies common sense," arguing that there was "never any question" that Barclays would receive the bulk of the money in the margin account.

Giddens, who is unwinding Lehman's brokerage under the terms of the Securities Investor Protection Act, said in a statement emailed to Dow Jones, "Barclays is attempting to contravene bankruptcy law and SIPA by laying claim to property that should be available to satisfy the claims of the LBI customers."

Barclays is asking Forrest for a hearing in its appeal, a request that is at her discretion.

Lehman in 2010 sued Barclays for billions, accusing the British bank of negotiating a discount not adequately disclosed to the court when it bought Lehman's broker-dealer unit in 2008. Barclays argued in the months-long trial that both sides negotiated in good faith, and the deal, approved by Judge James Peck of U.S. Bankruptcy Court in Manhattan just days after the investment bank collapsed into bankruptcy, was Lehman's best option.

Lehman pressed its case that in the tumultuous days of September 2008, when Barclays was finalizing its purchase of Lehman's brokerage, Barclays scrambled for more assets and negotiated with some Lehman executives a $5 billion discount. Lehman said its bankruptcy attorney, Weil, Gotshal & Manges partner Harvey Miller, and other Lehman representatives weren't informed of the discount and neither was Peck. Lehman sought to recover what it called more than $11 billion in ill-gotten gains by Barclays.

In his ruling, Peck wrote at several points about the so-called "clarification letter" that became a focal point of the case, a letter Peck agreed on at the time of the sale should be drafted to address several complications and list some assets moving over from Lehman to Barclays. On several occasions throughout Lehman's bankruptcy and the Barclays trial, Peck emphasized he had never approved the actual letter.

But in his ruling, Peck agreed with a key Barclays argument about the letter, saying, "While not expressly approved in so many words, the clarification letter is deemed approved" by the fact that it was known that it would be drafted, and that no party objected to it in court.

While Lehman fought to prove the discount, Giddens disputed the transfer of assets in the margin account and other accounts.

Last May, the two sides settled on another dispute, with the trustee agreeing to pay Barclays $1.1 billion for so-called clearance box assets that were worth $869 million at the time Barclays bought Lehman's brokerage business.

Peck late last year approved Lehman's historic $65 billion creditor payback plan, and distribution to its non-brokerage clients is expected to begin soon.

(Dow Jones Daily Bankruptcy Review covers news about distressed companies and those under bankruptcy protection.)

-By Joseph Checkler; Dow Jones Newswires; 212-416-2152; joseph.checkler@dowjones.com

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