UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

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1 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: ) Chapter 11 ENERGY CONVERSION DEVICES, INC., ) Case No TJT et al., 1 ) (Jointly Administered) Debtors, ) ) Hon. Thomas J. Tucker LIQUIDATION TRUSTEE S MOTION FOR AUTHORITY TO ISSUE DOCUMENT AND DEPOSITION SUBPOENAS TO MICRON TECHNOLOGY, INC., TYLER LOWREY, OVONYX, INC. AND OVONYX MEMORY TECHNOLOGY, LLC PURSUANT TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 2004 John Madden, the Liquidation Trustee of the Energy Conversion Devices Liquidation Trust (the Liquidation Trustee ), by and through its undersigned counsel, hereby moves (the Motion ) for entry of an order, pursuant to Rule 2004 ( Rule 2004 ) of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ) and Section 105(a) of Title 11 of the United States Code (the Bankruptcy Code ), (A) directing Micron Technology, Inc. ( Micron ), Ovonyx, Inc. ( Ovonyx ), Tyler Lowrey and Ovonyx Memory Technology, LLC ("OMT") to each produce documents identified on Exhibit A on or before January 29, 2018; and (B) authorizing the Liquidation Trustee to examine Tyler Lowrey and corporate designees of Micron, Ovonyx and OMT regarding the topics identified on Exhibit B on February 12, 2018 or on such other date as the parties agree. In support of the Motion, the Liquidation Trustee respectfully states as follows: 1 The Debtors in the jointly administered cases are Energy Conversion Devices, Inc. and United Solar Ovonic LLC tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 1 of 29

2 JURISDICTION AND VENUE 1. This Court has jurisdiction over this Motion pursuant to 28 U.S.C. 157 and This is a core proceeding pursuant to 28 U.S.C. 157(b)(2). 2. Venue is proper before this Court pursuant to 28 U.S.C and The statutory predicate for the relief sought herein is Section 105(a) of the Bankruptcy Code and Rule 2004 of the Bankruptcy Rules. BACKGROUND 4. On February 14, 2012 (the Petition Date ), Energy Conversion Devices, Inc. ("ECD") and United Solar Ovonic LLC (collectively, the Debtors ) filed voluntary chapter 11 petitions in the United States Bankruptcy Court for the Eastern District of Michigan (the Bankruptcy Court ). 5. On June 20, 2012, the Debtors filed their Second Amended Joint Plan of Liquidation... (the Plan ) [ECF 754]. The Plan provided for the creation of a liquidation trust (the Liquidation Trust ), to among other things, prosecute and resolve certain causes of action. Plan, Art. V.G.3.f. 6. On July 30, 2012, the Bankruptcy Court entered its Findings of Fact, Conclusions of Law and Order Approving Disclosure Statement and Confirming Second Amended Joint Plan of Liquidation of Energy Conversion Devices, Inc. and United Solar Ovonic LLC confirming the Plan (the Confirmation Order ) [ECF 1064]. 7. The Plan became effective on August 28, 2012 (the Effective Date ) [ECF 1220]. Pursuant to the Plan, all of the Debtors property was transferred to and is held by the Liquidation Trust, which was created by the Liquidation Trust Agreement dated August 28, tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 2 of 29

3 ECD's Interest in Ovonyx and Ovonyx's Assets 8. Prior to the Petition Date, ECD owned approximately 35.2%, on a fully diluted basis, of the stock of Ovonyx. At the time, Ovonyx engaged in developing, commercializing and licensing phase-change and chalcogenide semiconductor memory technology through joint development programs with semiconductor manufacturers and industrial partners in the United States and internationally. Prior to the Petition Date, the other equity interest owners included Mr. Lowrey, who had rights of first refusal. In addition to owning equity in Ovonyx, Mr. Lowrey was an officer of Ovonyx. 9. As this Court may recall, after a marketing process, and by order of this Court, ECD sold its equity interests in Ovonyx to Micron. See ECF Nos. 1085, It was represented to ECD, and reported to this Court, that during the marketing process Micron did not communicate with other equity owners in Ovonyx. See ECF 1274 at 25 (Aug. 22, 2012 Tr.). Specifically, the Court was informed that Micron and Misters Parkinson and Lowrey had no dialogue or discussion regarding the transaction and... there was no collusion between these parties in connection with the transaction. Id. 10. In addition to owning equity in Ovonyx, prior to the Petition Date ECD was a party to two contracts: (a) the Ovonic Information Handling Devices Development and Commercialization Contract executed on December 17, 1998 (the 1998 Agreement ); and (b) the "License Agreement" dated as of September 26, 2002 (the "2002 License Agreement"). Even though ECD sold its stock in Ovonyx, neither agreement was transferred to Micron or otherwise disposed of, and remains in full force and effect. Pursuant to the Plan, the Trust now holds ECD's rights under the 1998 Agreement and the 2002 License Agreement. The 1998 Agreement tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 3 of 29

4 11. Mr. Lowrey is the counterparty under the 1998 Agreement. According to the 1998 Agreement, [u]pon ECD s written request, the Entity shall thereafter pay every three months 0.5% of the Entity s subsequent revenues to ECD. The term Entity as used in the 1998 Agreement meant Ovonyx, and for the fiscal years prior to ECD s bankruptcy filing in 2012, Ovonyx paid 0.5% of its revenues to ECD (the Revenue Payments ). Since fiscal year 2011, ECD has not received any Revenue Payments or statements related to Revenue Payments. 12. In addition, the 1998 Agreement contains a right of first refusal provision, which provides that Mr. Lowrey granted to ECD a right of first refusal on any sale of stock in Ovonyx, on any sale of intellectual property in the field at any time, and on any Ovonyx stock or asset sales by Ovonyx. Since the end of fiscal year 2011, the Trust has not received any notices of Mr. Lowrey disposing of his stock in Ovonyx, or transferring intellectual property in the field or any notice of Ovonyx stock or assets being sold by Ovonyx. The 2002 License Agreement 13. The counterparty to the 2002 License Agreement is Ovonyx. Pursuant to the 2002 License Agreement, Ovonyx granted to Ovonyx Cognitive Computer, Inc. ("OCCI") a license of all patents "Licensable" by Ovonyx (as defined in the 2002 License Agreement). Because ECD owns equity in OCCI, ECD s investment in OCCI could be extremely valuable because of OCCI s license rights. 14. The Trust currently owns ECD s 95% of the equity interests in OCCI, and the ability to monetize such equity interests depends, in part, on understanding OCCI's rights under the 2002 License Agreement. In order to effectively monetize the OCCI asset, the Trust needs to know all patents previously or currently owned by or licensed to Ovonyx and all affiliates of Ovonyx (as defined in section 1.6 of the 2002 License Agreement) and any pending patent tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 4 of 29

5 applications; copies of all license agreements and joint development agreements entered into by Ovonyx; documentation evidencing any transfers of patents or patent licenses that Ovonyx has made since fiscal year 2011; and documentation evidencing any transfers of the 2002 License Agreement by Ovonyx to any third party. Recent Events 15. After the sale of the stock in Ovonyx, the Trust never received any Revenue Payments, never received any notices of dispositions as required under the 1998 Agreement, and never received any notices of patents that would be subject to licenses under the 2002 License Agreement But based on publicly available information, it appears that Ovonyx and the patents it holds are valuable. On information and belief, sometime after the sale of ECD s ownership of Ovonyx to Micron, Micron acquired the remaining shares of Ovonyx and merged Ovonyx with Micron. Ovonyx s patents (which total more than 300), along with hundreds of Micron-owned patents, apparently were assigned to OMT, but the ownership of OMT is unknown to the Trust. In addition, Micron and Intel announced a joint venture to develop and manufacture 3D XPoint technology, which began production in On information and belief, the 3D XPoint technology uses Ovonyx s patents. 17. On September 27, 2017, the Trust wrote to Mr. Lowrey, in his individual capacity and as an officer of Ovonyx, requesting documents and information relating to the 1998 Agreement and the 2002 License Agreement. Mr. Lowrey responded on October 11, 2017, stating that he had ceased serving as officer of Ovonyx on July 31, 2015 and that he did not 2 The Trust did receive from OMT a list of patents that OMT asserted were subject to the 2002 License Agreement tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 5 of 29

6 possess any information other than documentation I may have concerning my sales of Ovonyx shares. Mr. Lowrey then stated it is my understanding that any documentation relating to my sale of shares is subject to confidentiality agreement that I signed with the acquirer and therefore I am not at liberty to provide that information. Mr. Lowrey s October 11 letter confirmed that he did possess documents concerning a sale of Ovonyx shares, thus implicating the 1999 Agreement, but was unwilling to share there due to a purported confidentiality agreement. 18. The Trust followed up with Mr. Lowrey on October 27, 2017, and on November 5, 2017 Mr. Lowrey responded, stating Ovonyx has changed ownership to Micron and has new management. I believe the documents and information you request requires access to Ovonyx s corporate records. I do not have such access. Mr. Lowrey supplied the name of a contact person at Micron. As a result, on November 20, 2017, the Trust wrote to the Micron individual Mr. Lowrey identified, requesting the documents and information the Trust had requested of Mr. Lowrey. On December 8, 2017, Micron responded, stating that it would not produce any information because Micron had responded to a prior Rule 2004 subpoena to Ovonyx, and thus purportedly satisfied any obligation to provide documents and information relating to the matters raised in the letters to Mr. Lowrey. 19. In October 2015, the Trust filed a Rule 2004 motion, seeking authority to serve document and deposition subpoenas on Ovonyx (the 2015 Rule 2004 Motion ). See ECF No The 2015 Rule 2004 Motion was limited in scope as it sought only copies of a 1999 license and assignment agreement and the 2002 License Agreement, and copies of any agreements by and among Ovonyx, the Debtors, and any subsidiary or affiliate of the Debtors. This Court granted the 2015 Rule 2004 Motion. See ECF No Thereafter, the Trust obtained some information from Ovonyx, at the direction of Micron, but the documents and tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 6 of 29

7 information obtained 3 is different from the information sought now; indeed, the 2015 Rule 2004 Motion merely sought copies of agreements between the Debtors, their subsidiaries, and Ovonyx, and not any documents and information concerning rights under such agreements At this stage, the Trust has not received any of the requested information, and the likely sources are refusing to cooperate and/or claim they do not have the requested information. REQUEST FOR RELIEF 21. By this Motion, the Liquidation Trustee seeks entry of an order, substantially in the form attached hereto as Exhibit 1, authorizing the Liquidation Trustee to issue: (a) a document subpoena to each of Micron, Ovonyx, OMT, and Tyler Lowrey for the documents identified on Exhibit A attached hereto; and (b) a deposition subpoena to each of Micron, Ovonyx, OMT, and Tyler Lowrey for testimony with regard to the subjects set forth on Exhibit B attached hereto. 22. The Liquidation Trustee requests: (a) that such documents be produced for inspection and copying on or before January 29, 2018 at the office of Pepper Hamilton, LLP, 4000 Town Center, Suite 1800, Southfield, MI 48075, Attn: Robert S. Hertzberg, or at such other time or location as the parties may agree; and (b) that Tyler Lowrey and a corporate designee of Micron, Ovonyx and OMT appear for deposition upon oral examination at the office of Pepper Hamilton, LLP, 4000 Town Center, Suite 1800, Southfield, MI on February 12, 2018 or at such other time and place as the parties may agree. 3 The documents provided consisted of the 1998 Agreement, a 1999 agreement, then 2002 License Agreement, and a one-page amendment. 4 In 2016, the Trust sought additional information from Micron concerning rights under the 2002 License Agreement, which then passed the information request to Carlow Innovations LLC, which then became OMT tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 7 of 29

8 BASIS FOR RELIEF 23. Bankruptcy Rule 2004(a) states: On motion of any party in interest, the court may order the examination of any entity. Pursuant to Bankruptcy Rule 2004(b), the examination may relate to the acts, conduct, or property or the liabilities and financial condition of the debtor or to any matter which may affect the administration of the debtor s estate. Bankruptcy Rule 2004(c) provides that the attendance of an entity for examination and the production of documents may be compelled as provided in Bankruptcy Rule Bankruptcy Rule 9016 permits the issuance of subpoenas pursuant to Federal Rule of Civil Procedure ( Civil Rule ) As a general proposition, [Bankruptcy Rule] 2004 examinations are appropriate for revealing the nature and extent of the bankruptcy estate, and for discovering assets, examining transactions, and determining whether wrongdoing has occurred. In re Enron Corp., 281 B.R. 836, 840 (Bankr. S.D.N.Y. 2002) (citing In re Strecker, 251 B.R. 878, 882 (Bankr. D. Colo. 2000)). In this regard, courts have recognized that [Bankruptcy Rule] 2004 examinations are broad and unfettered and in the nature of fishing expeditions. Enron, 281 B.R. at Indeed, the scope of a Bankruptcy Rule 2004 examination is broader than the scope of discovery under Civil Rule 26. Moore v. Lang (In re Lang), 107 B.R. 130, 132 (Bankr. N.D. Ohio 1989). The scope also extends beyond the debtor to third parties. In re CIS Corp., 123 B.R. 488, 490 (S.D.N.Y. 1991) (stating that the scope of discovery under Bankruptcy Rule 2004 extends beyond the debtor to persons associated with him as well as those persons who may have had business dealings with the debtor ); In re Johns-Manville Corp., 42 B.R. 362, 364 (S.D.N.Y. 1984) (stating that inquiries under Bankruptcy Rule 2004 may cut a broad swath tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 8 of 29

9 through the debtor s affairs, those associated with him, and those who might have had business dealings with him ). 26. Good cause exists to grant this Motion. The Trust's rights under the 1998 Agreement and OCCI's rights under the 2002 License Agreement could be very valuable. Pursuant to the 1998 Agreement, if Ovonyx, or any successor in interest thereto, has had revenues, the Trust would be entitled to 0.5% of such revenue. In re Millennium Lab Holdings II, LLC, 562 B.R. 614, 626 (Bankr. D. Del. 2016) (stating that legitimate goals of Rule 2004 examinations include discovering assets and examining transactions ); In re Mavashev, 559 B.R. 332, 336 (Bankr. E.D.N.Y. 2016) (stating that the purpose of Rule 2004 is to assist the trustee in revealing the nature and extent of the estate; ascertaining assets; and discovering whether any wrongdoing has occurred ). And based on publicly available information, it is believed that Micron and Intel are selling products using Ovonyx patents, strongly suggesting that there has been revenue or there will soon be revenue. 27. In addition, Mr. Lowrey recently confirmed that he sold shares in Ovonyx, which, under the 1998 Agreement, ECD (and, now, the Trust) had a right of first refusal to acquire. But Mr. Lowrey has not provided any details, claiming that he cannot pursuant to a confidentiality agreement. 28. As explained above, the Trustee previously attempted to obtain the requested documents and information, but nothing has been produced. Rather, Mr. Lowrey refused to produce the documents he possesses based on a purported confidentiality agreement, with an known party, and pointed to Micron as the right party to provide documents. Micron, in turn, refused to provide documents by relying (incorrectly) on Ovonyx s prior responses to the 2015 Rule 2004 Motion tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 9 of 29

10 NOTICE 29. Notice of the Motion shall be provided to: (a) all parties who receive electronically filings from the Clerk of the Court using the ECF system; and (b) Tyler Lowrey, Micron, Ovonyx and OMT. 30. No previous request for the relief sought herein has been made to this or any other court. As set forth above, the 2015 Rule 2004 Motion requested different documents from the documents requested herein. Furthermore, the 2015 Rule 2004 Motion sought authorization to examine Tyler Lowrey on different topics (which deposition did not take place), and did not seek authorization to examine the corporate designees of Micron, Ovonyx or OMT. CONCLUSION WHEREFORE, the Liquidation Trustee respectfully requests that the Court grant this Motion and enter an order substantially in the form attached hereto as Exhibit 1. Dated: December 21, 2017 By: /s/ Deborah Kovsky-Apap PEPPER HAMILTON LLP Robert S. Hertzberg (P30261) Deborah Kovsky-Apap (P68258) 4000 Town Center, Suite 1800 Southfield, MI QUINN EMANUEL URQUHART & SULLIVAN LLP Eric Winston, Esq. (admission pending) 865 South Figueroa Street, 10 th Floor Los Angeles, CA Counsel to the Liquidation Trustee tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 10 of 29

11 EXHIBIT A DOCUMENTS TO BE PRODUCED DEFINITIONS 1. PERSON means any natural person, governmental agency, corporation, partnership, company, limited liability company, business, proprietorship, association, organization, joint venture, or group of natural persons. 2. OVONYX means Ovonyx, Inc. 3. ECD refers to Energy Conversion Devices, Inc. 4. The SECOND AMENDED PLAN refers to the Second Amended Joint Plan of Liquidation that was proposed on June 20, 2012 and confirmed by the Bankruptcy Court for the Eastern District of Michigan on July 30, To the extent not otherwise defined herein, all definitions contained in the SECOND AMENDED PLAN are hereby incorporated by reference. 5. The TRUST refers to the Liquidation Trusts created pursuant to the SECOND AMENDED PLAN, acting through it duly appointed trustee, John Madden. 6. The 2002 LICENSE AGREEMENT refers to that certain License Agreement dated as of September 26, The 1998 AGREEMENT refers to that certain Ovonic Information Handling Devices Development and Commercialization Contract executed on December 17, D XPoint means that certain 3D XpPoint technology being developed by Micron and Intel. 9. LOWREY refers to Tyler Lowrey. 10. CARLOW refers to Carlow Innovations LLC. 11. OMT means Ovonyx Memory Technology LLC and any predecessor in interest or successor in interest, including CARLOW. 12. MICRON means Micron Technology, Inc. 13. The words CONCERNING, RELEVANT TO, REGARDING, RELATING TO, and/or RELATED TO mean without limitation: containing; constituting; tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 11 of 29

12 stating; setting forth; recording; describing; reflecting; interpreting; identifying; related to; referring to; evidencing; confirming; supporting; contradicting; controverting; or in any way pertaining to, in whole or in part, that subject to which it refers or that contention to which it refers. 14. The word COMMUNICATION(S) shall mean and include any disclosure, transfer or exchange of information between two or more persons, whether orally or in writing, including, without limitation, any conversation or discussion by means of meeting, letter, telephone, note, memorandum, telegraph, telex, telecopier, electronic mail, or any other electronic or other medium, whether written, audio, or video. 15. The word DOCUMENT means and includes without limitation contracts, agreements, records, audio and videotape recordings, correspondence, communications, reports, studies, summaries, minutes, notes, agenda, bulletins, notices, announcements, instructions, charts, manuals, brochures, schedules, computer printouts, electronically-stored data, s, photographs, telegrams, teletypes, personal handwritten notes, memoranda of meetings and/or telephone conversations, any marginal comments appearing on any document, and any other documents. INSTRUCTIONS 1. References to entities or corporations other than natural PERSONS, including DEBTORS, ECD, OVONYX, CARLOW, OMT, MICRON and their affiliates, shall be deemed to include, in addition to the entity named, its divisions, departments, subsidiaries, affiliates, parents, predecessors, present or former officers, directors, employees, agents, representatives, accountants and attorneys, successors and all other persons acting or purporting to act on behalf of each such entity. 2. Each Request shall be construed independently and not with reference to any other Request for the purpose of limitation. The use of the singular form of any word includes the plural and vice versa; the past tense shall include the present tense and vice versa; and reference to any gender includes the other gender. The words and, or, and and/or shall tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 12 of 29

13 each be deemed to refer to both their conjunctive and disjunctive meanings and shall be interpreted in a manner consistent with the broader DOCUMENT production. The word including shall mean including but not limited to. The words every, all, and any shall mean each and every as well as any one. 3. If any Request cannot be complied with in full, it shall be complied with to the extent possible, with an explanation as to why full compliance is not possible. 4. In the event that any DOCUMENT responsive to these requests for production is subject to any claim of privilege (including work product), the responding party shall furnish a log identifying each such DOCUMENT by: identifying the person who prepared or authored the DOCUMENT and, if applicable, the persons who sent the DOCUMENT and to whom the DOCUMENT was sent (including copies) and the dates on which the DOCUMENT was prepared and transmitted; describing the nature of the DOCUMENT (e.g., letter, inter-office memorandum, notes, etc.) and, to the extent possible, the subject matter thereof; identifying any and all attachments or enclosures appurtenant to such DOCUMENTS; stating briefly the nature of the privilege asserted; and producing any non-privileged portions, attachments or enclosures to any such privileged DOCUMENT, and identifying the portion(s) of the DOCUMENT to which privilege is claimed. 5. For documents contained in Quick Books, please produce all data in Excel format and pdf format. 6. Where a responsive DOCUMENT is in a language other than English, state whether or not an English translation of the DOCUMENT exists. If a responsive DOCUMENT is in a language other than English and an English translation thereof does exist, produce both the original and the English language translation tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 13 of 29

14 7. Each copy of any DOCUMENT that contains any markings not appearing on the original, or is an alteration of the original, shall be considered a separate DOCUMENT for purposes of these discovery requests. 8. If possible, supply all financial data requested on a calendar year basis. If fiscal year data is provided, please specify the dates on which the fiscal years begin and end, unless otherwise specified in the Request. 9. For any information requested that is not readily available from your records in the form requested, furnish carefully prepared estimates, designated as such. Attach a statement of the basis for such estimates and identify the person or persons making them. 10. Records produced should be produced as ordinarily maintained in the course of business, and any indexes to such records should also be supplied. 11. All DOCUMENT requests set forth herein are for the period from June 30, 2011 to the present unless otherwise specified herein tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 14 of 29

15 REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS 1. All documents evidencing or referring to transfers of stock in Ovonyx, and the exercise, grant, vesting and termination of warrants or options, since June 30, 2011, including (a) all documents evidencing consideration provided in respect of such transfers or actions and (b) all communications concerning proposed or consummated transfers or actions of Ovonyx stock. 2. All documents evidencing or referring to dispositions or acquisitions of assets (including, but not limited to, intellectual property and licenses for intellectual property) of or by Ovonyx, whether inside or outside the ordinary course of business, since June 30, All notices provided to ECD or the Trust in respect of Request Nos. 1 and All documents evidencing or referring to patents previously or currently owned by Ovonyx and all affiliates of Ovonyx (as defined in section 1.6 of the 2002 License Agreement) and all pending patent applications. 5. All license agreements and joint development agreements entered into, modified, terminated, assumed or assigned by Ovonyx. 6. All documents referring to the 1998 Agreement and the 2002 License Agreement, including any notices relating to such agreements provided to ECD or the Trust. 7. All valuations of Ovonyx prepared since June 30, All documents referencing Ovonyx (including ownership of intellectual property), and patents held by or assigned to Ovonyx, in any marketing or product specifications materials, including in connection with switching, chalcogenide, phase-change (or modified phase change) and 3D XPoint tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 15 of 29

16 9. All financial statements of Ovonyx for fiscal years 2012 through 2017 and all quarterly financial statements since Ovonyx most recently completed fiscal year-end financial statements. 10. All documents evidencing or referring to agreements or transactions (proposed or consummated) that were dependent upon or based on the transfer of Ovonyx stock or asset(s) (including any intellectual property, license or collaboration agreement). 11. All documents evidencing or referring to employment agreements, consulting agreements or similar agreements, whether proposed or consummated, that provided for or referenced any transfer of Ovonyx stock or assets. 12. All documents evidencing or referring to licensing, profit sharing, earn-out, joint venture and similar agreements (proposed or consummated) that provided for or referenced any transfer of Ovonyx stock or assets. 13. All documents evidencing or referring to any merger, combination, consolidation or amalgamation of Ovonyx and OMT, or any transfer of stock or assets of Ovonyx to OMT. 14. All documents evidencing or referring to any sale or other disposition of Lowrey's stock in Ovonyx. 15. All documents evidencing or referring to any Person receiving an interest in OMT exchange for any rights in the stock or any asset of Ovonyx. 16. All documents evidencing ownership in OMT. 17. Financial statements of OMT for fiscal years 2015 and 2016 and year to date tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 16 of 29

17 EXHIBIT B MATTERS FOR EXAMINATION 1. All of the documents produced pursuant to Exhibit A tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 17 of 29

18 EXHIBIT 1 PROPOSED ORDER tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 18 of 29

19 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: ) Chapter 11 ENERGY CONVERSION DEVICES, INC., ) Case No TJT et al., 1 ) (Jointly Administered) Debtors, ) ) Hon. Thomas J. Tucker ORDER AUTHORIZING THE LIQUIDATION TRUSTEE TO ISSUE DOCUMENT AND DEPOSITION SUBPOENAS TO MICRON TECHNOLOGY, INC., TYLER LOWREY, OVONYX, INC. AND OVONYX MEMORY TECHNOLOGY, LLC PURSUANT TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 2004 Upon the motion (the Motion ) of John Madden, the Liquidation Trustee for the Energy Conversion Devices Liquidation Trust (the Liquidation Trustee ), for entry of an order (this Order ) pursuant to Rule 2004 of the Federal Rules of Bankruptcy Procedure authorizing the Liquidation Trustee to issue document and deposition subpoenas to Micron Technology, Inc. ( Micron ), Tyler Lowrey, Ovonyx, Inc. ( Ovonyx ) and Ovonyx Memory Technology, LLC ( OMT ) as more fully described in the Motion; and the Court being otherwise advised in the premises; and it appearing that the relief requested is the Motion is essential to the operation of the Liquidation Trust, and is in the best interests of the Trust, its creditors and other parties in interest; it appearing that this Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334; it appearing that this is a core proceeding pursuant to 28 U.S.C. 157(b)(2); it appearing that venue of this Motion in this District is proper pursuant to 28 U.S.C and 1409; it appearing that notice of this Motion and the opportunity for a hearing on this Motion 1 The Debtors in the jointly administered cases are Energy Conversion Devices, Inc. and United Solar Ovonic LLC tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 19 of 29

20 was appropriate under the particular circumstances and that no other or further notice need be given; and after due deliberation and good and sufficient cause appearing therefor; IT IS HEREBY ORDERED THAT: 1. The Motion is granted in its entirety. 2. The Liquidation Trustee may issue subpoenas for documents and depositions to Micron, Lowrey, Ovonyx and OMT. Each is directed to produce those documents identified on Exhibit A on or before January 29, The Liquidation Trustee may examine Lowrey and corporate designees of Micron, Ovonyx, and OMT regarding those topics identified on Exhibit B under oath at the offices of Pepper Hamilton, LLP, 4000 Town Center, Suite 1800, Southfield, MI on February 12, 2018 at 10:00 a.m. ET, or a date, time and place to be mutually agreed, and if no such agreement can be reached, at a date, time and place established by the Court. 4. The Court retains jurisdiction with respect to all matters arising from or related to the implementation of this Order tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 20 of 29

21 EXHIBIT 2 NOTICE OF MOTION AND OPPORTUNITY TO OBJECT tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 21 of 29

22 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: ) Chapter 11 ENERGY CONVERSION DEVICES, INC., ) Case No TJT et al., 1 ) (Jointly Administered) Debtors, ) ) Hon. Thomas J. Tucker NOTICE OF THE LIQUIDATION TRUSTEE S MOTION FOR AUTHORITY TO ISSUE DOCUMENT AND DEPOSITION SUBPOENAS TO MICRON TECHNOLOGY, INC., TYLER LOWREY, OVONYX, INC. AND OVONYX MEMORY TECHNOLOGY, LLC PURSUANT TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 2004 PLEASE TAKE NOTICE that on December 21, 2017, the Liquidation Trustee for the Energy Conversion Devices, Inc. Liquidation Trust (the Liquidation Trustee ) filed a Liquidation Trustee s Motion for Authority to Issue Document and Deposition Subpoenas to Tyler Lowrey and Ovonyx Memory Technology, LLC Pursuant to Federal Rule of Bankruptcy Procedure 2004 (the Motion ) seeking entry of an order authorizing the Liquidation Trustee to issue document and deposition subpoenas to MICRON TECHNOLOGY, INC., TYLER LOWREY, OVONYX, INC. AND OVONYX MEMORY TECHNOLOGY, LLC. PLEASE TAKE FURTHER NOTICE that your rights may be affected. You should read these papers carefully and discuss them with your attorney, if you have one. PLEASE TAKE FURTHER NOTICE that if you do not want the bankruptcy court to grant the Motion, or if you want the court to consider your views on the Motion, within seventeen (17) days, you or your lawyer must: 1. File with the Court a written response to the Motion 2 explaining your position at: United States Bankruptcy Court 211 W. Fort Street, Suite 2100 Detroit, MI The Debtors in the jointly administered cases are Energy Conversion Devices, Inc. and United Solar Ovonic LLC. 2 Response or answer must comply with Fed. R. Civ. P. 8(b), (c) and (e) tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 22 of 29

23 If you mail your response to the Court for filing, you must mail it early enough so that the Court will receive it on or before the date stated above. All attorneys are required to file pleadings electronically. You must also mail a copy to: Pepper Hamilton LLP Robert S. Hertzberg 4000 Town Center, Suite 1800 Southfield, MI Quinn Emanuel Urquhart & Sullivan LLP Eric Winston 865 South Figueroa Street, 10 th Floor Los Angeles, CA If a response or answer is timely filed and served, the clerk will schedule a hearing on the Motion and you will be served with a notice of the date, time and location of the hearing. If you or your attorney do not take these steps, the Court may decide that you do not oppose the relief sought to the motion and may enter and order granting that relief. PLEASE TAKE FURTHER NOTICE that the Liquidation Trustee will have this Motion served on the Master Service List. Respectfully submitted, Dated: December 21, 2017 /s/ Deborah Kovsky-Apap PEPPER HAMILTON LLP Robert S. Hertzberg (P30261) 4000 Town center, Suite 1800 Southfield, MI hertzbergr@pepperlaw.com kovskyd@pepperlaw.com QUINN EMANUEL URQUHART & SULLIVAN LLP Eric Winston, Esq. 865 South Figueroa Street, 10 th Floor Los Angeles, CA Telephone: ( Facsimile: (213) Counsel to the Liquidation Trustee tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 23 of 29

24 EXHIBIT 3 BRIEF NOT APPLICABLE tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 24 of 29

25 EXHIBIT 4 CERTIFICATE OF SERVICE tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 25 of 29

26 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: ) Chapter 11 ENERGY CONVERSION DEVICES, INC., ) Case No TJT et al., 1 ) (Jointly Administered) Debtors, ) ) Hon. Thomas J. Tucker CERTIFICATE OF SERVICE The undersigned certifies that on December 21, 2017, the Liquidation Trustee s foregoing Motion and Notice of Motion were electronically filed with the Clerk of the Court using the ECF system. Notice will be sent by operation of the Court s electronic filing system. Parties may access this filing through the Court s system. The undersigned further certifies that the Liquidation Trustee has engaged a Noticing Agent, which will serve this Motion on Tyler Lowrey, Micron Technology, Inc., Ovonyx, Inc., Ovonyx Memory Technology, LLC and the Master Service List, and will file a subsequent Proof of Service after it has performed the service. Respectfully submitted, Dated: December 21, 2017 /s/ Deborah Kovsky-Apap PEPPER HAMILTON LLP Robert S. Hertzberg (P30261) 4000 Town center, Suite 1800 Southfield, MI hertzbergr@pepperlaw.com kovskyd@pepperlaw.com 1 The Debtors in the jointly administered cases are Energy Conversion Devices, Inc. and United Solar Ovonic LLC tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 26 of 29

27 QUINN EMANUEL URQUHART & SULLIVAN LLP Eric Winston, Esq. 865 South Figueroa Street, 10 th Floor Los Angeles, CA Telephone: ( Facsimile: (213) Counsel to the Liquidation Trustee tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 27 of 29

28 EXHIBIT 5 AFFIDAVIT NOT APPLICABLE tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 28 of 29

29 EXHIBIT 6 DOCUMENTARY EXHIBITS NOT APPLICABLE tjt Doc 2596 Filed 12/21/17 Entered 12/21/17 20:36:25 Page 29 of 29

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