Footnote 8

98. Each of RBC, RBH, RBC DSI, RBC DSL, RBC USA and RBC CMC acted as thecontrol person, successor, agent, co-conspirator, co-venture partner and/or alter ego of the others asto the matters discussed herein, and they are collectively referred to herein as “RBC.”11. The Bank Defendants’ Proofs of Claim99. Each of the Bank Defendants except RBC – Citigroup, JP Morgan Chase, Barclays,BT/Deutsche Bank, CIBC, Merrill Lynch, CSFB, Toronto Dominion, and RBS – has filed one ormore proofs of claim against the Subordination Plaintiff in the Chapter 11 cases being jointlyadministered in this Court under consolidated case number 01-16034.C. Additional Defendants100. Defendant Sundance Industrial Partners L.P. (“Sundance Industrial”) is a Delawarelimited partnership. Its registered office is care of National Registered Agents Inc., 9 EastLoockerman Street, Suite 1B, Dover, Delaware 19901. Under Bankruptcy Code section 101(2)(B),Sundance Industrial is an affiliate of Plaintiff. As such, it is an insider of Plaintiff under BankruptcyCode section 101(31)(E).101. Not Used.102. Not Used.103. Not Used104. Defendant Caymus Trust is a Delaware business trust. Its registered office is careof Wilmington Trust Company, Rodney Square North, 1100 North Market Street, Wilmington,Delaware 19890.105. Defendant JGB Trust is a Delaware business trust. Its registered office is care ofWilmington Trust Company, Rodney Square North, 1100 North Market Street, Wilmington,Delaware 19890.106. Not Used.604041v1/007457-24-