Motion of the United States to Appoint Trustee

Plaintiff United States hereby moves this Court for entry of an order appointing Joseph G. Krauss of Washington, D.C. as Trustee pursuant to Section V of the Final Judgment in the above-captioned matter. The United States has informed defendant Mittal Steel Company, N.V. ("Mittal") that it is filing this motion, which, pursuant to the terms of the Final Judgment, Mittal may not oppose. In support of its motion, the United States files herewith a Memorandum in Support of Motion to Appoint Trustee and Declaration of Lowell R. Stern.

CERTIFICATE OF SERVICE

I hereby certify that on this 6^{thday of August 2007, I caused a copy of the foregoing Motion of The United States To Appoint Trustee and Proposed Order to be mailed, by U.S. mail, postage prepaid, to the attorneys listed below:}

For Mittal Steel Company N.V.:

Mark Leddy, Esquire
Brian Byrne, Esquire
Jeremy J. Calsyn, Esquire
Cleary Gottlieb Steen & Hamilton LLP
2000 Pennsylvania Avenue, NW
Washington, D.C. 20006