Case 17-22045-GLT Doc 260 Filed 05/26/17 Entered 05/26/17 183445 Desc Main Document Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA In Re rue 21, inc., et al., 1 Bankruptcy No. 17-22045-GLT Chapter 11 Debtors. (Jointly Administered) Leech Tishman Fuscaldo & Lampl, LLC, Movant, v. No Respondent. NOTICE OF APPEARANCE AND REQUEST FOR NOTICES OF WILMINGTON TRUST, NATIONAL ASSOCIATION PLEASE TAKE NOTICE that the undersigned hereby appears as local counsel for Wilmington Trust, National Association ( Wilmington Trust ), and pursuant to Rules 2002, 9007, and 9010 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ) requests that copies of any and all notices, pleadings, motions, orders to show cause, applications, presentments, petitions, memoranda, affidavits, declarations, orders, or other documents, filed or entered in this proceedings, be given to and served upon Matthew W. Silverman Pryor Cashman, LLP 7 Times Square New York, NY 10036 212-326-0824 msilverman@pryorcashman.com 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, include rue21, inc. (1645); Rhodes Holdco, Inc. (6922); r services llc (9425); and rue services corporation (0396). The location of the Debtors service address is 800 Commonwealth Drive, Warrendale, Pennsylvania 15086.
Case 17-22045-GLT Doc 260 Filed 05/26/17 Entered 05/26/17 183445 Desc Main Document Page 2 of 3 PLEASE TAKE FURTHER NOTICE that this request includes not only the notices and papers referred to in the Bankruptcy Rules and the Bankruptcy Code provisions specified above, but also includes all orders and notices of any application, motion, petition, pleading, request, complaint, or demand, whether formal or informal, whether written or oral, and whether transmitted or conveyed by mail, courier service, hand-delivery, telephone, facsimile transmission, electronically, or otherwise, that affect or seek to affect in any way the rights or interests of Wilmington Trust, or any other party-in-interest in this proceeding; or require or prohibit, or seek to require or prohibit, any act, delivery of any property, payment or other conduct by Wilmington Trust or any other party-in-interest. PLEASE TAKE FURTHER NOTICE that the foregoing constitutes a demand and request for service but does not constitute consent to the jurisdiction of the Bankruptcy Court. PLEASE TAKE FURTHER NOTICE that neither this Notice of Appearance nor any prior or later appearance, pleading, claim, or suit shall waive any right of Wilmington Trust to (a) have final orders in non-core matters entered only after de novo review by a District Court judge, (b) trial by jury in any proceeding so triable in these cases or any case, controversy, or proceeding related to this proceeding, (c) have the District Court withdraw the reference in any matter subject to mandatory or discretionary withdrawal, or (d) any other rights, claims, actions, defenses, setoffs or recoupments, under agreements, in law, in equity, or otherwise, all of which rights, claims, actions, defenses, setoffs, and recoupments are expressly reserved.
Case 17-22045-GLT Doc 260 Filed 05/26/17 Entered 05/26/17 183445 Desc Main Document Page 3 of 3 Respectfully Submitted, LEECH TISHMAN FUSCALDO & LAMPL, LLC Dated May 26, 2017 By /s/ David W. Lampl David W. Lampl PA I.D. No. 28900 525 William Penn Place 28 th Floor Pittsburgh, Pennsylvania 15219 (412) 261-1600 dlampl@leechtishman.com
Case 17-22045-GLT Doc 260-1 Filed 05/26/17 Entered 05/26/17 183445 Desc Certificate of Service Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA In Re rue 21, inc., et al., 1 Bankruptcy No. 17-22045-GLT Chapter 11 Debtors. (Jointly Administered) Leech Tishman Fuscaldo & Lampl, LLC, Movant, v. No Respondent. CERTIFICATE OF SERVICE I, David W. Lampl, hereby certify that on the 26th day of May, 2017, I submitted electronically the Notice of Appearance and Request for Notices of Wilmington Trust, National Association to the Clerk of the Court of the United States Bankruptcy Court for the Western District of Pennsylvania using the ECF System of the Court. The electronic case filing system sent a Notice of Electronic Filing to all attorneys of record who have consented in writing to accept this Notice as service of this document by electronic means. Respectfully Submitted, LEECH TISHMAN FUSCALDO & LAMPL, LLC Dated May 26, 2017 By /s/ David W. Lampl David W. Lampl PA I.D. No. 28900 525 William Penn Place 28 th Floor Pittsburgh, Pennsylvania 15219 (412) 261-1600 dlampl@leechtishman.com 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, include rue21, inc. (1645); Rhodes Holdco, Inc. (6922); r services llc (9425); and rue services corporation (0396). The location of the Debtors service address is 800 Commonwealth Drive, Warrendale, Pennsylvania 15086.
Case 17-22045-GLT Doc 260-1 Filed 05/26/17 Entered 05/26/17 183445 Desc Certificate of Service Page 2 of 2