Dennis F. Dunne, Esq. (admitted pro hac vice) Michael A. Condyles, Esq. (VA 27807)

Evan R. Fleck, Esq. (admitted pro hac vice) Peter J. Barrett, Esq. (VA 46179)

Michael W. Price, Esq. (admitted pro hac vice) 

MILBANK LLP

Jeremy S. Williams, Esq. (VA 77469) 

Brian H. Richardson, Esq. (VA 92477)

55 Hudson Yards KUTAK ROCK LLP 

New York, New York 10001 901 East Byrd Street, Suite 1000

Telephone: (212) 530-5000 Richmond, Virginia 23219-4071

Facsimile: (212) 530-5219 Telephone: (804) 644-1700

Facsimile: (804) 783-6192

Co-Counsel to Debtors in Possession 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

)

In re: ) Chapter 11

)

GEMSTONE SOLUTIONS GROUP, INC., et al.,

1

) Case No. 19-30258 (KLP)

)

Debtors. ) (Jointly Administered)

)

NOTICE OF MOTION AND NOTICE OF HEARING 

PLEASE TAKE NOTICE THAT on September 2, 2019, the above-captioned debtorsin-possession (collectively, the “Debtors”) filed the Debtors’ Sixth Motion for Entry of an Order 

Authorizing Them to Reject Certain Executory Contracts [Docket No. 1025] (the “Motion”) with 

the United States Bankruptcy Court for the Eastern District of Virginia (the “Court”). 

PLEASE TAKE FURTHER NOTICE THAT your rights may be affected. You 

should read these papers carefully and discuss them with your attorney, if you have one in these 

bankruptcy cases. (If you do not have an attorney, you may wish to consult one.) 

 

1

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

are: Gemstone Solutions Group, Inc. f/k/a Gymboree Group, Inc. (6587); Gemstone Solutions Intermediate 

Corporation f/k/a Gymboree Intermediate Corporation (1473); Gemstone Solutions Holding Corporation 

f/k/a Gymboree Holding Corporation (0315); Gemstone Solutions Wholesale, Inc. f/k/a Gymboree 

Wholesale, Inc. (6588); Gemstone Solutions Mark, Inc. f/k/a Gym-Mark, Inc. (6459); Gemstone Solutions 

Operations, Inc. f/k/a Gymboree Operations, Inc. (6463); Gemstone Solutions Distribution, Inc. f/k/a 

Gymboree Distribution, Inc. (8669); Gemstone Solutions Manufacturing, Inc. f/k/a Gymboree 

Manufacturing, Inc. (6464); Gemstone Solutions RS, LLC f/k/a Gymboree Retail Stores, LLC (6461); 

Gemstone Solutions Card, LLC f/k/a Gym-Card, LLC (5720); and Gemstone Solutions PR, LLC f/k/a 

Gymboree Island, LLC (1215). The Debtors’ service address is P.O. Box 192976, San Francisco, California 

94119. 

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PLEASE TAKE FURTHER NOTICE THAT in connection with the chapter 11 cases, 

an Order (I) Establishing Certain Notice, Case Management and Administrative Procedures and 

(II) Granting Related Relief [Docket No. 78] (the “Case Management Order”) was entered by the 

Court on January 17, 2019, which, among other things, prescribes the manner in which objections 

must be filed and served and when hearings will be conducted. A copy of the Case Management 

Order may be obtained at no charge at https://cases.primeclerk.com/gym or for a fee via PACER 

at http://www.vaeb.uscourts.gov. 

PLEASE TAKE FURTHER NOTICE THAT if you do not timely file and serve a 

written objection to the relief requested in the Motion, consistent with the Debtors’ Case 

Management Order, the Court may deem any opposition waived, treat the Motion as conceded and 

enter an order granting the relief requested in the Motion without further notice or a hearing. 

PLEASE TAKE FURTHER NOTICE THAT in accordance with the Case Management 

Order, if you wish to oppose the Motion, on or before 4:00 p.m. prevailing Eastern Time on 

September 13, 2019, or such shorter time as the Court may hereafter order, and of which 

you may receive subsequent notice, (the “Objection Deadline”), you must file with the Court, 

at the address shown below, a written objection pursuant to Local Bankruptcy Rule 9013-1 and 

the Case Management Order: 

Clerk of the Court 

United States Bankruptcy Court 

701 East Broad Street 

Richmond, Virginia 23219 

 PLEASE TAKE FURTHER NOTICE THAT in accordance with the Case Management 

Order, you must also serve a copy of your written objection on the Core Group, the 2002 List and 

the Affected Entities, as such terms are defined in the Case Management Order, on or before the 

Objection Deadline. 

PLEASE TAKE FURTHER NOTICE THAT the Motion is scheduled to be heard before 

the Court at the Hearing scheduled for September 16, 2019 at 1:00 p.m. prevailing Eastern Time, 

in the United States Bankruptcy Court, 701 East Broad Street, Room 5100, Richmond, Virginia 

23219. If you fail to file timely a written response and to attend the hearing even if a response is 

timely filed, the Court may consider any objection you may have waived and enter an order 

granting the relief requested. 

PLEASE TAKE FURTHER NOTICE THAT you should consult the Case Management 

Order before filing any written objection to the Motion. 

[Remainder of page intentionally left blank] 

Case 19-30258-KLP Doc 1026 Filed 09/02/19 Entered 09/02/19 21:24:38 Desc Main

 Document Page 2 of 3
Dated: September 2, 2019 /s/ Brian H. Richardson

Richmond, Virginia Michael A. Condyles, Esq. (VA 27807)

Peter J. Barrett, Esq. (VA 46179)

Jeremy S. Williams, Esq. (VA 77469) 

Brian H. Richardson, Esq. (VA 92477)

KUTAK ROCK LLP 

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 

Brian.Richardson@KutakRock.com

-andDennis F. Dunne, Esq. (admitted pro hac vice)

Evan R. Fleck, Esq. (admitted pro hac vice)

Michael W. Price, Esq. (admitted pro hac vice)

MILBANK LLP 

55 Hudson Yards

New York, New York 10001

Telephone: (212) 530-5000

Facsimile: (212) 530-5219

Email: ddunne@milbank.com

efleck@milbank.com

mprice@milbank.com

Co-Counsel for Debtors in Possession

Case 19-30258-KLP Doc 1026 Filed 09/02/19 Entered 09/02/19 21:24:38 Desc Main

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