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 AUGUST 22, 2019

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

22, 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 Ebates Performance Marketing Inc. [Docket No. 6642] and 

all previously adjourned informal responses, all such matters have been 

resolved.

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: None

Related Documents: None

Status: With respect to all previously adjourned informal responses, all such 

matters have been resolved.

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.

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 [Docket No. 6671] this matter has been 

resolved.

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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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: None

Related Documents: None

Status: With respect to all previously adjourned informal responses, all such 

matters have been resolved.

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: None

Related Documents: None

Status: With respect to all previously adjourned informal responses, all such 

matters have been resolved.

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 all previously adjourned informal responses, all such 

matters have been resolved.

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: With respect to all previously adjourned informal responses, all such 

matters have been resolved.

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-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 The Trustees of Vickerry Realty Co. Trust to Objection to 

Claim [Docket No. 7065]

B. 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 The Trustees of Vickerry Realty Co. Trust [Docket No. 

7065], Epoch Everlasting Play LLC f/k/a International Playthings LLC 

Claims [Docket No. 7072] and all previously adjourned informal 

responses, all such matters have been resolved.

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.

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9. "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 previously adjourned informal responses, all such 

matters have been resolved.

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-Ninth Omnibus Objection” Wayne Services Legacy Inc.'s Sixty-Ninth Omnibus 

Objection to Certain (A) Late-Filed Claims, (B) No Liability Claims, (C) Reduced and 

Reclassified Claims, and (D) Reduced Claims [Docket No. 7161]

Pending Responses: None

Related Documents: None

Status: With respect to all 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. "Seventieth Omnibus Objection” Wayne Services Legacy Inc.'s Seventieth Omnibus 

Objection to Certain No Liability Claims [Docket No. 7162]

Pending Responses: None

Related Documents: None

Status: With respect to all 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.

12. "Seventy-First Omnibus Objection” The TRU Taj Trust's Seventy-First Omnibus 

Objection to Certain No Liability Claims [Docket No. 7178]

Pending Responses: None

Related Documents: None

Status: With respect to all 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.

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13. "Seventy-Second Omnibus Objection” TRU Inc. Trust's Seventy-Second Omnibus 

Objection to Certain No Liability Claims [Docket No. 7179]

Pending Responses: None

Related Documents: None

Status: With respect to all 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.

14. "Seventy-Third Omnibus Objection” TRU Inc. Trust's Seventy-Third Omnibus 

Objection to Certain (A) No Liability Claims and (B) Reduced Claims [Docket No. 

7180]

Pending Responses: None

Related Documents: None

Status: With respect to all 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.

II. UNCONTESTED MATTERS

15. “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. 7195] 

Responses: None

Related Documents: None

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

submitted to the Court for entry.

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Richmond, Virginia

Dated: August 20, 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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