Case 16-10527-MFW Doc 3759 Filed 08/14/17 Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: TSAWD HOLDINGS, INC., et al., 1 Debtors. O2COOL, LLC, a Delaware limited liability company, v. Plaintiff, TSA STORES, INC.; BANK OF AMERICA, N.A.; WELLS FARGO BANK, NATIONAL ASSOCIATION; WILMINGTON SAVINGS FUND SOCIETY, FSB; YUSEN LOGISTICS (AMERICAS INC.; and OOCL (USA, INC. Defendants. Case No. 16-10527 (MFW (Jointly Administered Chapter 11 Adv. No. 16-51014 (MFW Related Docket Nos.: 52, 53, 76 & 97 CERTIFICATION OF COUNSEL REGARDING FIFTH STIPULATION FOR EXTENSION OF OOCL S DEADLINE TO REPLY IN SUPPORTS OF ITS MOTION FOR JUDGMENT ON THE PLEADINGS The undersigned, counsel to O2Cool, LLC (the Plaintiff hereby certifies as follows: 1. The Plaintiff and Defendant OOCL (USA, LLC have reached an agreement in principle to settle the disputes between them. In order to provide for additional time to document the settlement, the Plaintiff and Defendant have agreed to further extend the deadline by which the Defendant may file its Reply in support of its Motion for Judgment on the Pleadings. 1 The Debtors and the last four digits of their respective taxpayer identification numbers are as follows: TSAWD Holdings, Inc. (9008; Slap Shot Holdings, Corp. (8209; TSAWD, Inc. (2802; TSA Stores, Inc. (1120; TSA Gift Card, Inc. (1918; TSA Ponce, Inc. (4817; and TSA Caribe, Inc. (5664 (collectively, the Debtors. The Debtors were formerly known as: Sports Authority Holdings, Inc. (9008; Slap Shot Holdings, Corp. (8209; The Sports Authority, Inc. (2802; TSA Stores, Inc. (1120; TSA Gift Card, Inc. (1918; TSA Ponce, Inc. (4817; and TSA Caribe, Inc. (5664. {C0616825.1 }
Case 16-10527-MFW Doc 3759 Filed 08/14/17 Page 2 of 2 2. The undersigned and counsel to the Defendant OOCL (USA, Inc. have executed the attached Stipulation which further extends the deadline through and including October 13, 2017. WHEREFORE, the undersigned respectfully requests that the Court enter the proposed order attached hereto at the Court s convenience. Date: August 14, 2017 CAMPBELL & LEVINE, LLC /s/ Mark T. Hurford Mark T. Hurford (No. 3299 222 Delaware Avenue, Suite 1620 Telephone: (302 426-1900 Facsimile: (302 426-9947 E-mail: mhurford@camlev.com Counsel to Plaintiff, O2Cool, LLC {C0616825.1 } - 2 -
Case 16-10527-MFW Doc 3759-1 Filed 08/14/17 Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: TSAWD HOLDINGS, INC., et al., 1 Debtors. O2COOL, LLC, a Delaware limited liability company, v. Plaintiff, TSA STORES, INC.; BANK OF AMERICA, N.A.; WELLS FARGO BANK, NATIONAL ASSOCIATION; WILMINGTON SAVINGS FUND SOCIETY, FSB; YUSEN LOGISTICS (AMERICAS INC.; and OOCL (USA, INC. Defendants. Case No. 16-10527 (MFW (Jointly Administered Chapter 11 Adv. No. 16-51014 (MFW Related Docket Nos.: 52, 53, 76 & 97 FIFTH STIPULATION FOR EXTENSION OF OOCL S DEADLINE TO FILE REPLY IN SUPPORT OF ITS MOTION FOR JUDGMENT ON THE PLEADINGS WHEREAS, counsel for O2Cool, LLC (the Plaintiff and counsel for Defendant OOCL (USA, Inc., (the Defendant hereby stipulate and agree to an extension of the time for the Defendant s filing of a Reply in support of its Motion for Judgment on the Pleadings [D.I. 52], as follows: 1. Defendant shall have up to and including October 13, 2017 to file and serve a Reply in support of its Motion for Judgment on the Pleadings. 1 The Debtors and the last four digits of their respective taxpayer identification numbers are as follows: TSAWD Holdings, Inc. (9008; Slap Shot Holdings, Corp. (8209; TSAWD, Inc. (2802; TSA Stores, Inc. (1120; TSA Gift Card, Inc. (1918; TSA Ponce, Inc. (4817; and TSA Caribe, Inc. (5664 (collectively, the Debtors. The Debtors were formerly known as: Sports Authority Holdings, Inc. (9008; Slap Shot Holdings, Corp. (8209; The Sports Authority, Inc. (2802; TSA Stores, Inc. (1120; TSA Gift Card, Inc. (1918; TSA Ponce, Inc. (4817; and TSA Caribe, Inc. (5664. {C0616827.1 } 1
Case 16-10527-MFW Doc 3759-1 Filed 08/14/17 Page 2 of 2 Dated: August 14, 2017 CAMPBELL & LEVINE, LLC /s/ Mark T. Hurford Mark T. Hurford (DE 3299 222 Delaware Avenue, Suite 1620 Tel: (302 426-1900 Fax: (302 426-9947 Email: mhurford@camlev.com -and- HORWOOD MARCUS & BERK CHARTERED Jason M. Torf, Esq. 500 West Madison St. Suite 3700 Chicago, IL 60661 Tel: (312 606-3236 Fax: (312 267-2202 Email: jtorf@hmblaw.com MONTGOMERY MCCRACKEN WALKER & RHOADS LLP /s/ Richard G. Placey Richard G. Placey, Esq. 1105 North Market Street, 15 th Floor Tel: (302 504-7880 Fax: (302 504-7820 Email: rplacey@mmwr.com -and- Alfred J. Kuffler (pro hac vice Montgomery, McCracken, Walker & Rhoads, LLP 123 S. Broad Street, 24th Floor Philadelphia, PA 19109-1029 Tel: (215 772-7454 Fax: (215 731-3842 Counsel for OOCL (USA, Inc. Counsel for O2Cool, LLC {C0616827.1 } 2
Case 16-10527-MFW Doc 3759-2 Filed 08/14/17 Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: TSAWD HOLDINGS, INC., et al., 1 Debtors. O2COOL, LLC, a Delaware limited liability company, v. Plaintiff, TSA STORES, INC.; BANK OF AMERICA, N.A.; WELLS FARGO BANK, NATIONAL ASSOCIATION; WILMINGTON SAVINGS FUND SOCIETY, FSB; YUSEN LOGISTICS (AMERICAS INC.; and OOCL (USA, INC. Defendants. Case No. 16-10527 (MFW (Jointly Administered Chapter 11 Adv. No. 16-51014 (MFW Related Docket Nos.: 52, 53, 76 & 97 ORDER APPROVING THE FIFTH STIPULATION FOR EXTENSION OF OOCL S DEADLINE TO FILE REPLY IN SUPPORT OF ITS MOTION FOR JUDGMENT ON THE PLEADINGS Upon consideration of the Stipulation between the parties extending the deadline for OOCL (USA, Inc. to file its Reply brief in support of its Motion for Judgment on the Pleadings, and after due deliberation and sufficient cause appearing therefore; IT IS HEREBY ORDERED THAT: 1. The Fifth Stipulation for Extension of OOCL s Deadline to File Reply in Support of its Motion for Judgment on the Pleadings is hereby APPROVED; 1 The Debtors and the last four digits of their respective taxpayer identification numbers are as follows: TSAWD Holdings, Inc. (9008; Slap Shot Holdings, Corp. (8209; TSAWD, Inc. (2802; TSA Stores, Inc. (1120; TSA Gift Card, Inc. (1918; TSA Ponce, Inc. (4817; and TSA Caribe, Inc. (5664 (collectively, the Debtors. The Debtors were formerly known as: Sports Authority Holdings, Inc. (9008; Slap Shot Holdings, Corp. (8209; The Sports Authority, Inc. (2802; TSA Stores, Inc. (1120; TSA Gift Card, Inc. (1918; TSA Ponce, Inc. (4817; and TSA Caribe, Inc. (5664. {C0616826.1 } 1
Case 16-10527-MFW Doc 3759-2 Filed 08/14/17 Page 2 of 2 2. OOCL (USA, LLC shall have up to and including October 13, 2017 to file and serve the Reply in support of its Motion for Judgment on the Pleadings. 3. This Court shall retain jurisdiction to resolve any disputes or controversies arising from or related to this Stipulation and Order. Dated: The Honorable Mary F. Walrath United States Bankruptcy Judge {C0616826.1 } 2
Case 16-10527-MFW Doc 3759-3 Filed 08/14/17 Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: TSAWD HOLDINGS, INC., et al., 1 Debtors. O2COOL, LLC, a Delaware limited liability company, v. Plaintiff, TSA STORES, INC.; BANK OF AMERICA, N.A.; WELLS FARGO BANK, NATIONAL ASSOCIATION; WILMINGTON SAVINGS FUND SOCIETY, FSB; YUSEN LOGISTICS (AMERICAS INC.; and OOCL (USA, INC. Defendants. Case No. 16-10527 (MFW (Jointly Administered Chapter 11 Adv. No. 16-51014-MFW CERTIFICATE OF SERVICE I, Mark T. Hurford, Esquire, do hereby certify that on this 14 th day of August, 2017, I caused a copy of the foregoing Fifth Stipulation for Extension of OOCL s Deadline to File Reply in Support of its Motion for Judgment on the Pleadings to be served on the following parties by CM/ECF electronic notification and U.S. Mail: Andrew L. Magaziner, Esquire Young Conaway Stargatt & Taylor, LLP Rodney Square 1000 North King Street Gregory A. Taylor, Esq. Benjamin W. Keenan, Esq. Ashby & Geddes, P.A. 500 Delaware Avenue, 8 th Floor P.O. Box 1150 Wilmington, DE 19899-1150 1 The Debtors and the last four digits of their respective taxpayer identification numbers are as follows: TSAWD Holdings, Inc. (9008; Slap Shot Holdings, Corp. (8209; TSAWD, Inc. (2802; TSA Stores, Inc. (1120; TSA Gift Card, Inc. (1918; TSA Ponce, Inc. (4817; and TSA Caribe, Inc. (5664 (collectively, the Debtors. The Debtors were formerly known as: Sports Authority Holdings, Inc. (9008; Slap Shot Holdings, Corp. (8209; The Sports Authority, Inc. (2802; TSA Stores, Inc. (1120; TSA Gift Card, Inc. (1918; TSA Ponce, Inc. (4817; and TSA Caribe, Inc. (5664. {C0559731.1 }
Case 16-10527-MFW Doc 3759-3 Filed 08/14/17 Page 2 of 2 Donald E. Rothman, Esq. Paul S. Samson, Esq. Reimer & Braunstein LLP Three Center Plaza, Suite 600 Boston, Massachusetts 02108 May Orenstein, Esq. Brown Rudnick, LLP 7 Times Square New York, NY 10036 Kevin J. Simard, Esq Douglas R. Gooding, Esq. Choate, Hall & Stewart Two International Place Boston, MA 02110 Simon E. Fraser, Esq. Cozen O Conner 1201 North Market Street, Suite 1001 Daniel B. Butz, Esq. Morris Nichols Arsht & Tunnell 1201 North Market Street, 16 th Floor Wilmington, DE 19899 Mark D. Collins, Esq. Andrew M. Dean, Esq. Richards, Layton & Finger, P.A. One Rodney Square 920 North King Street Rachel Hollander, Esq. Olasov + Hollander LLP 33 West 60 th Street 4 th Floor New York, NY 10023 Richard G. Placey, Esq. Montgomery McCracken Walker & Rhoads LLP 1105 North Market Street, 15 th Floor Alfred J. Kuffler, Esq. Montgomery McCracken Walker & Rhoads LLP 123 South Broad Street, 24 th Floor Philadelphia, PA 19109 Dated: August 14, 2017 CAMPBELL & LEVINE, LLC /s/ Mark T. Hurford Mark T. Hurford (Bar No. 3299 {C0559731.1 }