Case 17-22045-GLT Doc 1713 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Main Document Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF PENNSYLVANIA In re: Case No. 17-22045 (GLT, et al., 1 Chapter 11 Reorganized Debtors. (Jointly Administered, et al. Related to Docket No. 1677 Movants, v. Claimants identified on the schedules attached hereto, Respondents. CERTIFICATION OF COUNSEL REGARDING AMENDED PROPOSED ORDER SUSTAINING DEBTORS SIXTEENTH OMNIBUS OBJECTION The undersigned hereby certifies that and its affiliates (collectively, the Reorganized Debtors amended the proposed order attached to the Reorganized Debtors Sixteenth Omnibus Objection to Certain Proofs of Claim (No Liability Claims (the Sixteenth Omnibus Objection [Doc. No. 1677] to remove claim numbers 2176 and 2320, filed by the Texas Comptroller of Public Accounts, from the schedule of no liability claims. Attached hereto as Exhibit A is a copy of the amended proposed Order Sustaining Debtors Sixteenth Omnibus Objection to Certain Proofs of Claim (No Liability Claims. A redline of the changes to the proposed order is attached hereto as Exhibit B. 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are: (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 1713 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Main Document Page 2 of 2 Dated: August 16, 2018 Jonathan S. Henes, P.C. (admitted pro hac vice George Klidonas (admitted pro hac vice KIRKLAND & ELLIS LLP KIRKLAND & ELLIS INTERNATIONAL LLP 601 Lexington Avenue New York, New York 10022 Telephone: (212 446-4800 Facsimile: (212 446-4900 Counsel to the Reorganized Debtors /s/ Jared S. Roach Eric A. Schaffer (PA I.D. #30797 Jared S. Roach (PA I.D. #307541 REED SMITH LLP 225 Fifth Avenue Pittsburgh, Pennsylvania 15222 Telephone: (412 288-3131 Facsimile: (412 288-3063 Local Counsel to the Reorganized Debtors 2
Case 17-22045-GLT Doc 1713-1 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit A Page 1 of 6 Exhibit A Amended Proposed Order
Case 17-22045-GLT Doc 1713-1 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit A Page 2 of 6 IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA In re: Case No. 17-22045 (GLT, et al., 1 Chapter 11 Reorganized Debtors. (Jointly Administered, et al., Related to Docket No. Movants, v. Claimants identified on the schedules attached hereto, Respondents. ORDER SUSTAINING REORGANIZED DEBTORS SIXTEENTH OMNIBUS OBJECTION TO CERTAIN PROOFS OF CLAIM (NO LIABILITY CLAIMS Upon the objection (the Objection 2 of the above-captioned debtors (collectively, the Debtors and after the effective date of their plan of reorganization, the Reorganized Debtors for entry of an order (this Order : (a disallowing and expunging the No Liability Claims identified on Schedule 1 attached hereto; and (b granting related relief, all as more fully set forth in the Objection; and after due deliberation, it is HEREBY ORDERED THAT: 1. The Objection is sustained as set forth herein. 1 2 The Reorganized Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are: (1645; Rhodes Holdco, Inc. (6922; r services llc (9425; and rue services corporation (0396. The location of the Reorganized Debtors service address is: 800 Commonwealth Drive, Warrendale, Pennsylvania 15086. Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Objection.
Case 17-22045-GLT Doc 1713-1 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit A Page 3 of 6 2. Each No Liability Claim identified on Schedule 1 to this Order is disallowed and expunged in its entirety. 3. The Reorganized Debtors Notice and Claims Agent, which maintains the claims register in these chapter 11 cases, is authorized and directed to update the claims register maintained in these chapter 11 cases to reflect the relief granted in this Order. 4. Each No Liability Claim and the Objections by the Reorganized Debtors to each such No Liability Claim constitute a separate contested matter as contemplated by Bankruptcy Rule 9014. This Order will be deemed a separate order with respect to each No Liability Claim. 5. Notwithstanding the relief granted in this Order and any actions taken pursuant to such relief, nothing in this Order shall be deemed: (a an admission as to the validity of any prepetition claim against a Debtor entity; (b a waiver of any party s right to dispute any prepetition claim on any grounds; (c a promise or requirement to pay any prepetition claim; (d an implication or admission that any particular claim is of a type specified or defined in this Objection or any order granting the relief requested by this Objection; (e a request or authorization to assume any prepetition agreement, contract, or lease pursuant to section 365 of the Bankruptcy Code; or (f a waiver of the Reorganized Debtors rights under the Bankruptcy Code or any other applicable law. 6. The terms and conditions of this Order will be immediately effective and enforceable upon its entry. 7. The Reorganized Debtors are authorized to take all actions necessary to effectuate the relief granted pursuant to this Order in accordance with the Objection. 8. This Court shall retain jurisdiction to resolve any dispute arising from or related to this Order. 2
Case 17-22045-GLT Doc 1713-1 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit A Page 4 of 6 Prepared by: Reed Smith LLP (Local Counsel to the Reorganized Debtors Pittsburgh, Pennsylvania Dated:, 2018 THE HONORABLE GREGORY L. TADDONIO UNITED STATES BANKRUPTCY JUDGE 3
Case 17-22045-GLT Doc 1713-1 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit A Page 5 of 6 Schedule 1 No Liability Claims
Schedule 1 No Liability Claims 1 Claim(s to be Expunged Claim or Schedule Number Date Filed Name of Claimant Claim Amount Debtor Reason for Disallowance 2255 10/31/2017 City of Fayetteville 847 07/21/2017 City of Porterville 1800 08/08/2017 3129565 Schedule E/F Part 2 6/20/2017 1737 08/08/2017 2170 10/09/2017 2035 08/11/2017 Case 17-22045-GLT Doc 1713-1 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit A Page 6 of 6 City of Virginia Beach One Jeanswear Group, Inc. Orly Shoe Corporation Tennessee Department of Revenue Village of Chicago Ridge $150.00 Priority $0.00 General Unsecured $116.15 General Unsecured $280.00 General Unsecured $49,619.30 General Unsecured $306,144.98 General Unsecured $8,700.57 Priority $0.00 General Unsecured $71.74 General Unsecured rue services corporation 3129575 Schedule E/F Part 2 6/20/2017 Vis Style Corp $78,483.00 General Unsecured rue services corporation In re, et al., Case No. 17-22045 (GLT USBC, Western District of PA Page 1 of 1 1 Refer to pages 6 and 7 in Objection pertinent to stated grounds
Case 17-22045-GLT Doc 1713-2 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit B Page 1 of 7 Exhibit B Redline of Changes to Proposed Order (Attached
Case 17-22045-GLT Doc 1713-2 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit B Page 2 of 7 IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA In re: Case No. 17-22045 (GLT, et al., 1 Chapter 11 Reorganized Debtors. (Jointly Administered, et al., Related to Docket No. Movants, v. Claimants identified on the schedules attached hereto, Respondents. ORDER SUSTAINING REORGANIZED DEBTORS SIXTEENTH OMNIBUS OBJECTION TO CERTAIN PROOFS OF CLAIM (NO LIABILITY CLAIMS Upon the objection (the Objection 2 of the above-captioned debtors (collectively, the Debtors and after the effective date of their plan of reorganization, the Reorganized Debtors for entry of an order (this Order : (a disallowing and expunging the No Liability Claims identified on Schedule 1 attached hereto; and (b granting related relief, all as more fully set forth in the Objection; and after due deliberation, it is HEREBY ORDERED THAT: 1. The Objection is sustained as set forth herein. 1 2 The Reorganized Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are: (1645; Rhodes Holdco, Inc. (6922; r services llc (9425; and rue services corporation (0396. The location of the Reorganized Debtors service address is: 800 Commonwealth Drive, Warrendale, Pennsylvania 15086. Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Objection.
Case 17-22045-GLT Doc 1713-2 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit B Page 3 of 7 2. Each No Liability Claim identified on Schedule 1 to this Order is disallowed and expunged in its entirety. 3. The Reorganized Debtors Notice and Claims Agent, which maintains the claims register in these chapter 11 cases, is authorized and directed to update the claims register maintained in these chapter 11 cases to reflect the relief granted in this Order. 4. Each No Liability Claim and the Objections by the Reorganized Debtors to each such No Liability Claim constitute a separate contested matter as contemplated by Bankruptcy Rule 9014. This Order will be deemed a separate order with respect to each No Liability Claim. 5. Notwithstanding the relief granted in this Order and any actions taken pursuant to such relief, nothing in this Order shall be deemed: (a an admission as to the validity of any prepetition claim against a Debtor entity; (b a waiver of any party s right to dispute any prepetition claim on any grounds; (c a promise or requirement to pay any prepetition claim; (d an implication or admission that any particular claim is of a type specified or defined in this Objection or any order granting the relief requested by this Objection; (e a request or authorization to assume any prepetition agreement, contract, or lease pursuant to section 365 of the Bankruptcy Code; or (f a waiver of the Reorganized Debtors rights under the Bankruptcy Code or any other applicable law. 6. The terms and conditions of this Order will be immediately effective and enforceable upon its entry. 7. The Reorganized Debtors are authorized to take all actions necessary to effectuate the relief granted pursuant to this Order in accordance with the Objection. 8. This Court shall retain jurisdiction to resolve any dispute arising from or related to this Order. 2
Case 17-22045-GLT Doc 1713-2 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit B Page 4 of 7 Prepared by: Reed Smith LLP (Local Counsel to the Reorganized Debtors Pittsburgh, Pennsylvania Dated:, 2018 THE HONORABLE GREGORY L. TADDONIO UNITED STATES BANKRUPTCY JUDGE 3
Case 17-22045-GLT Doc 1713-2 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit B Page 5 of 7 Schedule 1 No Liability Claims
Schedule 1 No Liability Claims 1 Claim(s to be Expunged Claim or Schedule Number Date Filed Name of Claimant Claim Amount Debtor Reason for Disallowance 2255 10/31/2017 City of Fayetteville 847 07/21/2017 City of Porterville 1800 08/08/2017 3129565 6/20/2017 1737 08/08/2017 2170 10/09/2017 2320 01/29/2018 2176 10/11/2017 Case 17-22045-GLT Doc 1713-2 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit B Page 6 of 7 City of Virginia Beach One Jeanswear Group, Inc.- discuss Orly Shoe Corporation Tennessee Department of Revenue Texas Comptroller of Public Accounts Texas Comptroller of Public Accounts $150.00 Priority $0.00 General Unsecured $116.15 General Unsecured $280.00 General Unsecured $49,619.30 General Unsecured $306,144.98 General Unsecured $8,700.57 Priority $0.00 General Unsecured $132,573.28 Priority $9,093.80 General Unsecured $69,402.66 Priority $6,133.49 General Unsecured rue services corporation In re, et al., Case No. 17-22045 (GLT USBC, Western District of PA Page 1 of 2 1 Refer to pages 6 and 7 in Objection pertinent to stated grounds
Schedule 1 No Liability Claims 1 Claim(s to be Expunged Claim or Schedule Number Date Filed Name of Claimant Claim Amount Debtor Reason for Disallowance 2035 08/11/2017 Village of Chicago Ridge 3129575 Schedule E/F Part 2 6/20/2017 Vis Style Corp Case 17-22045-GLT Doc 1713-2 Filed 08/16/18 Entered 08/16/18 17:01:17 Desc Exhibit B Page 7 of 7 $71.74 General Unsecured $0.00 $0.00 $0.00 $78,483.00 Administrative Priority Secured Priority General Unsecured rue services corporation In re, et al., Case No. 17-22045 (GLT USBC, Western District of PA Page 2 of 2 1 Refer to pages 6 and 7 in Objection pertinent to stated grounds