Michael A. Condyles (VA 27807)

Peter J. Barrett (VA 46179)

Jeremy S. Williams (VA 77469)

KUTAK ROCK LLP

901 East Byrd Street, Suite 1000

Richmond, Virginia 23219-4071

Telephone: (804) 644-1700

Facsimile: (804) 783-6192

Co-Counsel to Wayne Services Legacy Inc.,

the TRU Inc. Trust, Toys “R” Us Property II, LLC and

Giraffe Junior Holdings, LLC

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

)

In re: ) Chapter 11

)

TOYS “R” US, INC., et al.,

1 ) Case No. 17-34665 (KLP)

)

Debtors. ) (Jointly Administered)

)

AGENDA FOR HEARING ON 

MOTIONS SCHEDULED FOR JUNE 27, 2019

PLEASE TAKE NOTICE that the following matters are scheduled for hearing on June 

27, 2019 at 11:00 a.m. (prevailing Eastern Time):

I. OMNIBUS OBJECTIONS

1. “Twenty-Eighth Omnibus Objection” Debtors' Twenty-Eighth Omnibus Objection to 

Certain (A) Amended Priority Claims, (B) Amended Claims, (C) Reduced Amount 

Claims, (D) Exact Duplicate Claims, (E) Incorrect Debtor Claims, (F) Reduced 

Amount and Incorrect Debtor Claims, (G) No Liability Claims, (H) Reclassified 

Claims, (I) Satisfied Claims, and (J) Substantive Duplicate Claims [Docket No. 5976]

Pending Responses:

A. Ebates Performance Marketing Inc.'s Response to Debtors' Twenty-Eight 

Omnibus Objection to Certain (A) Amended Priority Claims (B) 

Amended Claim, (C) Reduced Amount Claims, (D) Exact Duplicate 

Claims, (E) Incorrect Debtor Claims, (F) Reduced Amount and Incorrect 

Debtor Claims, (G) No Liability Claims, (H) Reclassified Claims, (I) 

 

1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 

number, are set forth in the Order (I) Directing Joint Administration of Chapter 11 Cases and (II) Granting 

Related Relief [Docket No. 78]. The location of the Debtors’ service address is One Geoffrey Way, Wayne, 

New Jersey 07470.

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Satisfied Claims, and (J) Substantive Duplicate Claims [Docket No. 

6642]

Related Documents: None

Status: With respect to the claimants set forth on Exhibit A, this matter is being 

set for final hearing on August 22, 2019 or such other day as may be agreed 

upon by the parties, with additional briefing and/or discovery deadlines to 

be set by the agreement of the parties or ordered by the Court where 

necessary.

With respect to all other claimants for which a response was not timely 

filed or alternative treatment was not otherwise agreed to, an order granting 

the relief requested has previously been entered by the Court.

2. "Fifty-First Omnibus Objection” Debtors' Fifty-First Omnibus Objection to Certain (A) 

Amended Priority Claims, (B) Amended Claims, (C) Reduced Amount Claims, (D) 

Substantive Duplicate Claims, (E) Insufficient Documentation Claims, (F) No Liability 

Claims, (G) Satisfied Claims, (H) Late-Filed Claims, and (I) Incorrect Debtors Claims 

[Docket No. 6272]

Pending Responses:

A. C&T International's Response to Debtors' Fifty-First Omnibus Objection 

to Certain (A) Amended Priority Claims, (B) Amended Claims, (C) 

Reduced Amount Claims, (D) Substantive Duplicate Claims, (E) 

Insufficient Documentation Claims, (F) No Liability Claims, (G) 

Satisfied Claims, (H) Late-Filed Claims, and (I) Incorrect Debtors 

Claims [Docket No. 6474]

Related Documents: None

Status: This matter is resolved with respect to C&T International [Docket No. 

6474].

This matter is going forward with respect to RPAI Fort Myers Page Field, 

L.L.C. 

With respect to the claimants set forth on Exhibit A, this matter is being 

set for final hearing on August 22, 2019 or such other day as may be agreed 

upon by the parties, with additional briefing and/or discovery deadlines to 

be set by the agreement of the parties or ordered by the Court where 

necessary.

With respect to all other claimants for which a response was not timely 

filed or alternative treatment was not otherwise agreed to, an order granting 

the relief requested has been previously entered by the Court.

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3. "Fifty-Fifth Omnibus Objection” Debtors' Fifty-Fifth Omnibus Objection to Certain 

(A) Reduced Amount Claims, (B) No Liability Claims, (C) Satisfied Claims, (D) 

Incorrect Debtors Claims, and (E) Late-Filed Claims [Docket No. 6276]

Pending Responses:

A. Response of the Travelers Indemnity Company to the Debtors’ FiftyFifth Omnibus Objection to Claim [Docket No. 6671]

Related Documents: None

Status: With respect to The Travelers Indemnity Company and its property 

casualty insurance affiliates, this matter is being adjourned to a hearing

date to be agreed upon by the parties, with additional briefing and/or 

discovery deadlines to be set by the agreement of the parties or ordered by 

the Court where necessary.

With respect to all other claimants for which a response was not timely 

filed or alternative treatment was not otherwise agreed to, an order granting 

the relief requested has been previously entered by the Court.

4. "Fifty-Ninth Omnibus Objection” Wayne Services Legacy Inc.'s Fifty-Ninth Omnibus 

Objection to Certain (A) Amended Priority Claims, (B) Reduced Amount Claims, (C) 

Reduced and Reclassified Claims, (D) No Liability Claims, (E) Amended Claims, and 

(F) Insufficient Documentation Claims [Docket No. 6495]

Pending Responses:

A. Response to Wayne Services Legacy Inc.'s Fifty-Ninth Omnibus 

Objection to Certain (A) Amended Priority Claims, (B) Reduced 

Amount Claims, (C) Reduced and Reclassified Claims, (D) No Liability 

Claims, (E) Amended Claims, and (F) Insufficient Documentation 

Claims and Request for Additional Time [Docket No. 6640]

Related Documents: None

Status: This matter is resolved with respect to CSFB 2005-C3 Retail 8801, LLC 

[Docket No. 6640].

This matter is going forward with respect to 3309-3139 Oak View Drive 

Holdings, LLC.

With respect to the claimants set forth on Exhibit A, this matter is being 

set for final hearing on August 22, 2019 or such other day as may be agreed 

upon by the parties, with additional briefing and/or discovery deadlines to 

be set by the agreement of the parties or ordered by the Court where 

necessary.

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With respect to all other claimants for which a response was not timely 

filed or alternative treatment was not otherwise agreed to, an order granting 

the relief requested has been previously entered by the Court.

5. "Sixtieth Omnibus Objection” Wayne Services Legacy Inc.'s Sixtieth Omnibus 

Objection to Certain (A) Reclassified Claims, (B) Reduced and Reclassified Claims, 

(C) Amended Claims, (D) Reduced Claims, (E) No Liability Claims, (F) Insufficient 

Documentation Claims, and (G) Satisfied Claims [Docket No. 6787]

Pending Responses:

A. Response of RPT Realty LLC, Successor-in-Interest to RamcoGershenson Properties, L.P. to Notice of Wayne Services Legacy Inc.’s 

Sixtieth Omnibus Objection to Claims [Docket No. 6855]

Related Documents: None

Status: This matter is going forward with respect to Ramco-Gershenson Properties, 

L.P. [Docket No. 6855]

With respect to the claimants set forth on Exhibit A, this matter is being 

set for final hearing on August 22, 2019 or such other day as may be agreed 

upon by the parties, with additional briefing and/or discovery deadlines to 

be set by the agreement of the parties or ordered by the Court where 

necessary.

With respect to all other claimants for which a response was not timely 

filed or alternative treatment was not otherwise agreed to, an order granting 

the relief requested has been previously entered by the Court.

6. "Sixty-Third Omnibus Objection” TRU Inc. Trust's Sixty-Third Omnibus Objection to 

Certain (A) No Liability Claims and (B) Exact Duplicate Claim [Docket No. 6870]

Pending Responses: None

Related Documents: None

Status: With respect to the claimants set forth on Exhibit A, this matter is being 

set for final hearing on August 22, 2019 or such other day as may be agreed 

upon by the parties, with additional briefing and/or discovery deadlines to 

be set by the agreement of the parties or ordered by the Court where 

necessary.

With respect to all other claimants for which a response was not timely 

filed or alternative treatment was not otherwise agreed to, an order granting 

the relief requested has been previously entered by the Court.

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7. "Sixty-Fourth Omnibus Objection” Wayne Services Legacy Inc.'s Sixty-Fourth 

Omnibus Objection to Certain (A) Reclassified Claims, (B) Reduced and Reclassified 

Claims, (C) Amended Claims, (D) Reduced Claims, (E) No Liability Claims, (F) 

Insufficient Documentation Claims, (G) Duplicate Claims, and (H) Late-Filed Claims

[Docket No. 6887]

Pending Responses: None

Related Documents: None

Status: This matter is going forward with respect to Meridian CenterCal, L.L.C.

With respect to the claimants set forth on Exhibit A, this matter is being 

set for final hearing on August 22, 2019 or such other day as may be agreed 

upon by the parties, with additional briefing and/or discovery deadlines to 

be set by the agreement of the parties or ordered by the Court where 

necessary.

With respect to all other claimants for which a response was not timely 

filed or alternative treatment was not otherwise agreed to, an order granting 

the relief requested has been previously entered by the Court.

8. "Sixty-Fifth Omnibus Objection” TRU Inc. Trust's Sixty-Fifth Omnibus Objection to 

Certain (A) No Liability Claims and (B) Late-Filed Claims [Docket No. 6984]

Pending Responses:

A. Response by FTC Commercial Corp., as Assignee of PBC International 

Inc. to the TRU Inc. Trust's Sixty-Fifth Omnibus Objection to Certain 

(A) No Liability Claims and (B) Late-Filed Claims [Docket No. 7060]

Related Documents: 

Status: This matter is going forward with respect to FTC Commercial Corp.

[Docket No. 7060]

With respect to all other claimants for which a response was not timely filed 

or alternative treatment was not otherwise agreed to, an order granting the 

relief requested has been or will submitted to the Court for entry.

9. "Sixty-Sixth Omnibus Objection” Wayne Services Legacy Inc.'s Sixty-Sixth Omnibus 

Objection to Certain (A) Reclassified Claims, (B) Reduced and Reclassified Claims, 

(C) Amended Claims, (D) Reduced Claims, (E) No Liability Claims, (F) Insufficient 

Documentation Claims, (G) Duplicate Claims, and (H) Late-Filed Claims [Docket No. 

6986]

Pending Responses:

A. Response of Claimant HCL Goodyear Centerpointe LLC to Wayne 

Services Legacy Inc.'s Sixty-Sixth Omnibus Objection to Certain (A) 

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Reclassified Claims, (B) Reduced and Reclassified Claims, (C) 

Amended Claims, (D) Reduced Claims, (E) No Liability Claims, (F) 

Insufficient Documentation Claims, (G) Duplicate Claims, and (H) LateFiled Claims [Docket No. 7055]

B. Response of The Trustees of Vickerry Realty Co. Trust to Objection to 

Claim [Docket No. 7065]

C. Response of Epoch Everlasting Play LLC f/k/a International Playthings 

LLC to Wayne Services Legacy Inc.'s Sixty-Sixth Omnibus Objection to 

Certain (A) Reclassified Claims, (B) Reduced and Reclassified Claims, 

(C) Amended Claims, (D) Reduced Claims, (E) No Liability Claims, (F) 

Insufficient Documentation Claims, (G) Duplicate Claims, and (H) LateFiled Claims [Docket No. 7072]

Related Documents: None

Status: With respect to HCL Goodyear Centerpointe LLC [Docket No. 7055] this 

matter has been resolved.

With respect to the claimants set forth on Exhibit A, this matter is being 

set for final hearing on August 22, 2019 or such other day as may be agreed 

upon by the parties, with additional briefing and/or discovery deadlines to 

be set by the agreement of the parties or ordered by the Court where 

necessary.

With respect to all other claimants for which a response was not timely 

filed or alternative treatment was not otherwise agreed to, an order granting 

the relief requested has been or will submitted to the Court for entry.

10. "Sixty-Seventh Omnibus Objection” Wayne Services Legacy Inc.'s Sixty-Sixth 

Omnibus Objection to Certain (A) Reclassified Claims, (B) Reduced and Reclassified 

Claims, (C) Amended Claims, (D) Reduced Claims, (E) No Liability Claims, (F) 

Insufficient Documentation Claims, (G) Duplicate Claims, and (H) Late-Filed Claims

[Docket No. 6988]

Pending Responses: None

Related Documents: None

Status: With respect to all other claimants for which a response was not timely 

filed or alternative treatment was not otherwise agreed to, an order granting 

the relief requested has been or will submitted to the Court for entry.

11. "Sixty-Eighth Omnibus Objection” Toys "R" Us Property Company II, LLC's SixtyEighth Omnibus Objection to Certain (A) Satisfied Claims, and (B) No Liability Claims

[Docket No. 6996]

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Pending Responses: None

Related Documents: 

A. Amended Schedule 1 (Satisfied Claims) [Docket No. 7006]

Status: This matter is going forward with respect to all claimants for which a 

response was not timely filed or alternative treatment was not otherwise 

agree to.

II. UNCONTESTED MATTERS

12. “Motion to Close Certain Cases” Joint Motion to Close Certain Chapter 11 Cases 

Pursuant to 11 U.S.C. § 350(A) and Federal Rule of Bankruptcy Procedure 3022

[Docket No. 7028] 

Responses: None

Related Documents: None

Status: An amended order resolving certain informal responses has been or will be 

submitted to the Court for entry.

13. “Motion to Extend” Joint Motion for Entry of an Order Extending the Claims Objection 

Bar Date [Docket No. 7049]

Pending Responses: None

Related Documents: None

Status: An order granting the relief requested has been or will be submitted to the 

Court for entry.

III. CONTESTED MATTERS

14. “Motion to Approve Settlement” Joint Motion for Entry of an Order (I) Approving the 

Settlement Agreement, (II) Certifying A Class of Former Employees for Settlement 

Purposes Only, (III) Appointing Class Counsel and Class Representative, (IV) 

Approving the Form and Manner of Notice of the Class Certification and Settlement, 

(V) Setting the Aggregate Recovery of the Class Under the Global Settlement 

Agreement, and (VI) Granting Related Relief [Docket No. 7056] 

Responses:

A. Response filed by Claressa Rodriguez [Docket No. 7079]

B. Response filed by Kym Zatterberg [Docket No. 7080]

Related Documents: None

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Status: This matter is going forward.

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Richmond, Virginia

Dated: June 25, 2019

/s/ Jeremy S. Williams

KUTAK ROCK LLP

Michael A. Condyles (VA 27807)

Peter J. Barrett (VA 46179)

Jeremy S. Williams (VA 77469)

901 East Byrd Street, Suite 1000

Richmond, Virginia 23219-4071

Telephone: (804) 644-1700

Facsimile: (804) 783-6192

Email: Michael.Condyles@KutakRock.com

Peter.Barrett@KutakRock.com

Jeremy.Williams@KutakRock.com

Co-Counsel to Wayne Services Legacy Inc.,

the TRU Inc. Trust, Toys “R” Us Property II, 

LLC and Giraffe Junior Holdings, LLC

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EXHIBIT A

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Claimant Claim Number Claim Objection No. Status

Accuen Media 16756 28 Final hearing set for August 22, 2019

eBates Performance Marketing, Inc. 15538 28 Final hearing set for August 22, 2019

Resolution Media 16773 28 Final hearing set for August 22, 2019

RetailMeNot, Inc. 13150 28 Final hearing set for August 22, 2019

Oath Holdings Inc. 16350 51 Final hearing set for August 22, 2019

The Travelers Indemnity Company 2811 55 This matter is being adjourned to a date to be determined

The Travelers Indemnity Company 22542 55 This matter is being adjourned to a date to be determined

UE 675 Route I LLC 22471 59 Final hearing set for August 22, 2019

ARC SPSANTX001, LLC 20630 60 Final hearing set for August 22, 2019

Zurich Services Corporation 22333 63 Final hearing set for August 22, 2019

Centerpoint Owner, LLC 16395 64 Final hearing set for August 22, 2019

Hickory Ridge Owner, LLC 17199 64 Final hearing set for August 22, 2019

IN Retail Fund Woodfield Commons, LLC 16946 64 Final hearing set for August 22, 2019

IRC University Corssings, LLC 17234 64 Final hearing set for August 22, 2019

Lozier Corporation 3056 64 Final hearing set for August 22, 2019

360i, LLC 16423 66 Final hearing set for August 22, 2019

Epoch Everlastying Play 1123, 22176 66 Final hearing set for August 22, 2019

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Claimant Claim Number Claim Objection No. Status

G&I VIII Riverchase, L.P. 22700 66 Final hearing set for August 22, 2019

Smart Trike MNF, PTE, Ltd. 16604 66 Final hearing set for August 22, 2019

The Trustees of Vickerry Realty Co. Trust 16650 66 Final hearing set for August 22, 2019

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