: In re : Chapter 11 : DANA CORPORATION, et al., : Case No (BRL) : Debtors. : (Jointly Administered) :

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1 STROOCK & STROOCK & LAVAN LLP Michael J. Sage (MS-6998) Kristopher M. Hansen (KH-4679) Shannon Lowry Nagle (SN-5793) 180 Maiden Lane New York, NY Tel (212) Fax (212) UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK x In re Chapter 11 DANA CORPORATION, et al., Case No (BRL) Debtors. (Jointly Administered) x FOURTH SUPPLEMENTAL VERIFIED STATEMENT OF STROOCK & STROOCK & LAVAN LLP PURSUANT TO BANKRUPTCY RULE 2019 KRISTOPHER M. HANSEN certifies as follows 1. I am an attorney at law and a member of the firm of Stroock & Stroock & Lavan LLP ( Stroock ). I am an attorney in good standing admitted to practice before the courts of the State of New York and the United States District Courts for the Southern and Eastern Districts of New York. 2. On March 22, 2006, Stroock filed the Verified Statement of Stroock & Stroock & Lavan LLP Pursuant to Bankruptcy Rule 2019 (the Statement ) in connection with its representation of certain holders (collectively, the Ad Hoc Committee ), for themselves and on behalf of certain funds and managed accounts, of the 6.5% Notes due 2008; 6.5% Notes due 2009; % Notes due 2010; 9.0% Notes due 2011; 5.85% Notes due 2015; 7% Notes due

2 2028; and 7% Notes due 2029 issued by Dana Corporation (collectively, the Notes ), in connection with the chapter 11 cases of the above-captioned debtors and debtor-in-possession (collectively, the Debtors ). 3. On April 7, 2006, Stroock filed the Supplemental Verified Statement of Stroock & Stroock & Lavan LLP Pursuant to Bankruptcy Rule 2019 (the First Supplemental Statement ) to amend and supersede the Statement, due to certain changes to the composition of the Ad Hoc Committee between the filing of the Statement and the First Supplemental Statement. On July 6, 2006, Stroock filed the Second Supplemental Statement of Stroock & Stroock & Lavan LLP Pursuant to Bankruptcy Rule 2019 (the Second Supplemental Statement ) to supersede the First Supplemental Statement, due to certain changes to the composition of the Ad Hoc Committee between the filing of the First Supplemental Statement and the Second Supplemental Statement. On October 5, 2006, Stroock filed the Third Supplemental Statement of Stroock & Stroock & Lavan LLP Pursuant to Bankruptcy Rule 2019 (the Third Supplemental Statement ) to supersede the Second Supplemental Statement due to certain changes to the composition of the Ad Hoc Committee between the filing of the Second Supplemental Statement and the Third Supplemental Statement. 4. Since the time that the Third Supplemental Statement was filed, the composition of the Ad Hoc Committee has once again changed. Therefore, pursuant to Rule 2019, Stroock submits this fourth supplemental verified statement (the Fourth Supplemental Statement ) to supersede the Third Supplemental Statement. The names and addresses of the members of the Ad Hoc Committee as of the date hereof are set forth on Annex A attached hereto. -2-

3 5. As of the date hereof, each member of the Ad Hoc Committee is a creditor of the Debtors. As of the date hereof, the aggregate face value of Notes held by the members of the Ad Hoc Committee represents approximately $1.312 billion of the total outstanding face amount of $1.578 billion of unsecured notes issued by Dana Corporation. 6. The members of the Ad Hoc Committee have asked Stroock to represent their interests during the pendency of these chapter 11 cases. 7. In addition, Stroock represents Precision Partners Holding Company and its affiliated companies, including Cannon Automotive Solutions, The Electromac Group, Inc., Nationwide Precision Products Corporation, Greenfield Tool and Manufacturing, Inc., Motorwheel Commercial Vehicle Systems, Inc. and Hayes-Lemmerz Mexico, S.A. de C.V. (collectively, the Precision Companies ) in connection with the Precision Companies trade claims against the Debtors. 8. As of the date hereof, Stroock does not hold a claim against the Debtors. However, Stroock may at some future time seek to have its fees and disbursements paid by the Debtors estates pursuant to the Bankruptcy Code. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] -3-

4 9. The undersigned certifies that this Fourth Supplemental Statement is true and accurate to the best of his knowledge and belief. Stroock reserves the right to revise and supplement this Fourth Supplemental Statement as need be. Dated November 10, 2006 New York, New York STROOCK & STROOCK & LAVAN LLP /s/ Kristopher M. Hansen Michael J. Sage (MS-6998) Kristopher M. Hansen (KH-4679) Shannon Lowry Nagle (SN-5793) 180 Maiden Lane New York, NY Tel (212) Fax (212)

5 ANNEX A

6 Members of the Ad Hoc Committee of Dana Noteholders AVENUE CAPITAL MANAGEMENT II, LP 535 Madison Avenue, 14th Floor JP MORGAN VENTURES CORPORATION 270 Park Avenue New York, NY BANC OF AMERICA SECURITIES 9 West 57th St., 2nd Floor BEAR STEARNS & CO., INC. 383 Madison Avenue, 6th Floor New York, NY BLACKPORT CAPITAL FUND LTD. 345 Park Avenue New York, NY BRENCOURT ADVISORS 600 Lexington Avenue, Suite 800 CASPIAN CAPITAL ADVISORS LLC 500 Mamaroneck Avenue, Suite 101 Harrison, NY CHICAGO FUNDAMENTAL INVESTMENT PARTNERS LLC 71 S. Wacker, Suite 3495 Chicago, IL CITADEL INVESTMENT GROUP LLC 131 South Dearborn Street Chicago, IL CITIGROUP GLOBAL CAPITAL MARKETS 390 Greenwich St., 4th Fl. New York, NY CONCORDIA ADVISORS LLC 1350 Ave of the Americas CREDIT SUISSE FIRST BOSTON 11 Madison Avenue, 4th Floor New York, NY CYPRESS MANAGEMENT ADVISORS LLC 100 Pine Street, Suite 2700 San Francisco, CA JANA PARTNERS 200 Park Avenue, Suite 3300 New York, NY LATIGO PARTNERS, LP 590 Madison Avenue 9th Floor LEHMAN BROTHERS INC. Distressed and Special Situations 745 7th Avenue, 3rd Floor LEHMAN BROTHERS INC. Global Principal Opportunities 745 7th Avenue, 19th Floor MERRILL LYNCH 4 World Financial Center, 7th Floor New York, NY ORE HILL PARTNERS LLC 650 Fifth Avenue, 9th Floor OWL CREEK ASSET MANAGEMENT 640 Fifth Avenue, 20th Floor POLYGON INVESTMENT PARTNERS, LP 598 Madison Avenue, 14th Floor POST ADVISORY GROUP, LLC Wilshire Boulevard, Suite 1400 Los Angeles, CA QUADRANGLE GROUP, LLC 375 Park Avenue New York, NY REDWOOD MASTER FUND LTD. 910 Sylvan Ave Englewood Cliffs, NJ 07632

7 D.E. SHAW LAMINAR PORTFOLIOS LLC 120 West 45th Street New York, NY DAVIDSON KEMPNER CAPITAL MANAGEMENT LLC 885 Third Avenue, Suite 3300 DEUTSCHE BANK 60 Wall Street New York, NY DIMAIO AHMAD CAPTIAL LLC 245 Park Avenue 44th Floor New York, NY DUNE CAPITAL MANAGEMENT LP 623 Fifth Avenue, 30th Floor EOS CREDIT OPPORTUNITIES 320 Park Avenue, 9th Floor FORTRESS INVESTMENT GROUP LLC 1345 Avenue of the Americas, 46th Floor New York, NY FRANKLIN MUTUAL ADVISORS 101 John F. Kennedy Parkway Short Hills, NJ GK CAPITAL, LLC 910 Sylvan Way Englewood Cliffs, NJ GSO CAPITAL PARTNERS 280 Park Avenue New York, NY HBK INVESTMENTS 300 Crescent Court, Suite 700 Dallas, TX REGIMENT CAPITAL ADVISORS, LLC 222 Berkeley Street, 12th Floor Boston, MA RESOLUTION PARTNERS 909 Third Ave, 30th Floor SANDELL ASSET MANAGEMENT CORP. 40 West 57th Street, 26th Floor SCOGGIN CAPITAL MANAGEMENT 660 Madison Avenue, 20th Floor New York, NY SENECA CAPITAL INVESTMENTS 590 Madison Avenue, 28th Floor SILVER POINT CAPITAL, LP Two Greenwich Plaza, 1st Floor Greenwich, CT STRATEGIC VALUE PARTNERS, LLC 80 Field Point Road Greenwich, CT TACONIC CAPITAL, LP 450 Park Avenue 9th Floor TRAFELET DELTA FUNDS 900 Third Avenue, 5th Floor VENOR CAPITAL MANAGEMENT LP Times Square Tower 7 Times Square, Suite 3505 New York, NY VIKING GLOBAL INVESTORS LP 55 Railroad Avenue Greenwich, CT JP MORGAN SECURITIES INC. 270 Park Avenue New York, NY

alg Doc 769 Filed 04/02/12 Entered 04/02/12 18:49:42 Main Document Pg 1 of 7

alg Doc 769 Filed 04/02/12 Entered 04/02/12 18:49:42 Main Document Pg 1 of 7 Pg 1 of 7 AKIN GUMP STRAUSS HAUER & FELD LLP One Bryant Park New York, New York 10036 (212) 872-1000 (Telephone) (212) 872-1002 (Facsimile) Michael S. Stamer David H. Botter Abid Qureshi Counsel to Second