144512.00013

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 for 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)

)

PROPOSED AGENDA FOR MATTERS SCHEDULED 

FOR SEPTEMBER 16, 2019, AT 1:00 P.M. (PREVAILING EASTERN TIME) 

I. DEBTOR MOTIONS

1. “Motion for Expedited Hearing.” Motion to Shorten Notice Period and for Expedited 

Hearing [Docket No. 1032] 

Responses Received: None 

Related Documents: 

 

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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A. Debtors' Motion to Amend the Order Authorizing the Debtors to 

Retain and Compensate Professionals Utilized in the Ordinary 

Course of Business [Docket No. 1031] 

B. Notice of Hearing and Notice of Motions [Docket No. 1033] 

Status: This matter is going forward on an uncontested basis. 

2. “OCP Amendment Motion.” Debtors' Motion to Amend the Order Authorizing the 

Debtors to Retain and Compensate Professionals Utilized in the Ordinary Course of 

Business [Docket No. 1031] 

Responses Received: 

A. Objection to Debtors’ Motion to Amend the Order Authorizing the 

Debtors to Retain and Compensate Professionals Utilized in the 

Ordinary Course of Business [Docket No. 1047] 

Related Document: 

A. Motion to Shorten Notice Period and for Expedited Hearing 

[Docket No. 1032]

B. Notice of Hearing and Notice of Motions [Docket No. 1033]

Status: This matter is going forward. 

3. “Third Motion to Authorize Contract Rejection.” Debtors' Motion for Entry of an Order 

Authorizing Them to Reject Certain Executory Contracts [Docket No. 797] 

Responses Received: None 

Related Documents: 

A. Notice of Motion and Notice of Hearing [Docket No. 798] 

Status: This matter was previously adjourned but is going forward on an 

uncontested basis. 

4. “Sixth Motion to Authorize Contract Rejection.” Debtors' Sixth Motion for Entry of an 

Order Authorizing Them to Reject Certain Executory Contracts [Docket No. 1025] 

Responses Received: None 

Related Documents: 

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A. Notice of Motion and Notice of Hearing [Docket No. 1026]

B. Notice of Hearing and Notice of Motion(s) [Docket No. 1033]

Status: This matter is going forward on an uncontested basis. 

III. ADVERSARY PROCEEDINGS 

1. “Pocrass Adversary.” 

A. “WARN Settlement.” Joint Motion Pursuant to 11 U.S.C. § 105 and Fed. R. 

Bankr. P. 7023 and 9019 for Entry of an Order (I) Approving a Settlement Relating 

to WARN Act-Related Claims, (II) Certifying a Class of WARN Act Claimants for 

Settlement Purposes Only, (III) Appointing Class Counsel and Class 

Representative, (IV) Approving Form and Manner of Notice of Class Certification 

and Settlement, and (V) Granting Related Relief [Docket No. 990] 

Responses Received: 

A. Objection to Joint Motion Pursuant to 11 U.S.C. § 105 and Fed. R. 

Bankr. P. 7023 and 9019 for Entry of an Order (I) Approving a 

Settlement Relating to WARN Act-Related Claims, (II) Certifying a 

Class of WARN Act Claimants for Settlement Purposes Only, (III) 

Appointing Class Counsel and Class Representative, (IV) 

Approving Form and Manner of Notice of Class Certification and 

Settlement, and (V) Granting Related Relief [Docket No. 1030] 

Related Documents: 

A. Adversary Class Action Complaint [Docket No. 1, Adv. Case No. 

19-03010] 

B. Debtors’ Motion to Stay Adversary Proceeding [Docket No. 6, Adv. 

Case No. 19-03010] 

C. First Amended Adversary Class Action Complaint [Docket No. 14, 

Adv. Case No. 19-03010] 

D. Plaintiff’s Response in Opposition to Debtor’s Motion to Stay 

Adversary Proceeding [Docket No. 18, Adv. Case No. 19-03010] 

E. Order [Docket No. 32, Adv. Case No. 19-03010] 

F. Order Further Continuing Hearing on Debtors’ Motion to Stay 

Adversary Proceeding and Pre-Trial Conference [Docket No. 36, 

Adv. Case No. 19-03010] 

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G. Hearing continued by Agreement pending settlement negotiations

[Docket No. 38, Adv. Case No. 19-03010] 

H. Pre-Trial Conference Continued by Agreement pending settlement 

negotiations [Docket No. 39, Adv. Case No. 19-03010] 

I. Pre-Trial Conference Continued [Docket No. 42, Adv. Case No. 19-

03010] 

J. Hearing continued [Docket No. 43, Case No. 19-03010] 

K. Hearing continued [Docket No. 46, Adv. Case No. 19-03010] 

L. Pre-Trial Conference continued [Docket No. 47, Adv. Case No. 19-

03010] 

M. Pre-Trial Conference continued [Docket No. 48, Adv. Case No. 19-

03010] 

N. Hearing continued [Docket No. 49, Adv. Case No. 19-03010] 

O. Pre-Trial Conference continued [Docket No. 52, Adv. Case No. 19-

03010] 

P. Hearing continued [Docket No. 53, Adv. Case No. 19-03010] 

Q. Hearing continued [Docket No. 54, Adv. Case No. 19-03010] 

R. Pre-Trial Conference continued [Docket No. 54, Adv. Case No. 19-

03010] 

S. Notice of Joint Motion Pursuant to 11 U.S.C. § 105 and Fed. R. 

Bankr. P. 7023 and 9019 for Entry of an Order (I) Approving a 

Settlement Relating to WARN Act-Related Claims, (II) Certifying a 

Class of WARN Act Claimants for Settlement Purposes Only, (III) 

Appointing Class Counsel and Class Representative, (IV) 

Approving Form and Manner of Notice of Class Certification and 

Settlement, and (V) Granting Related Relief [Docket No. 991] 

T. Debtors’ Reply to Objection to Joint Motion Pursuant to 11 U.S.C. 

§ 105 and Fed. R. Bankr. P. 7023 and 9019 for Entry of an Order 

(I) Approving a Settlement Relating to WARN Act-Related Claims, 

(II) Certifying a Class of WARN Act Claimants for Settlement 

Purposes Only, (III) Appointing Class Counsel and Class 

Representative, (IV) Approving Form and Manner of Notice of Class 

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Certification and Settlement, and (V) Granting Related Relief 

[Docket No. 1037] 

U. Joinder of WARN Plaintiff Katherine Pocrass to Debtors’ Reply to 

Objection to Joint Motion Pursuant to 11 U.S.C. § 105 and Fed. R. 

Bankr. P. 7023 and 9019 for Entry of an Order (I) Approving a 

Settlement Relating to WARN Act-Related Claims, (II) Certifying a 

Class of WARN Act Claimants for Settlement Purposes Only, (III) 

Appointing Class Counsel and Class Representative, (IV) 

Approving Form and Manner of Notice of Class Certification and 

Settlement, and (V) Granting Related Relief [Docket No. 1038] 

V. Declaration of René S. Roupinian in Support of Plaintiff’s Joinder 

to Debtors’ Reply to Objection to Joint Motion Pursuant to 11 

U.S.C. § 105 and Fed. R. Bankr. P. 7023 and 9019 for Entry of an 

Order (I) Approving a Settlement Relating to WARN Act-Related 

Claims, (II) Certifying a Class of WARN Act Claimants for 

Settlement Purposes Only, (III) Appointing Class Counsel and Class 

Representative, (IV) Approving Form and Manner of Notice of Class 

Certification and Settlement, and (V) Granting Related Relief

[Docket No. 1039] 

Status: This matter is going forward.

IV. SALE MATTERS 

1. “Cure Objections.” Notice of Adjournment of Unresolved Cure Objections to Monday, 

September 16, 2019 at 1:00 P.M. (prevailing Eastern Time) [Docket No. 971] 

Responses Received: None 

Related Documents: 

A. Order (I)(A) Approving Bidding Procedures, (B) Approving J&J 

Stalking Horse Purchase Agreement, (C) Scheduling an Auction and 

Approving Form and Manner of Notice Thereof, (D) Approving 

Assumption and Assignment Procedures and (E) Scheduling the 

Sale Hearing; (II) Approving (A) the Sale(s), Free and Clear of 

Encumbrances and (B) Assumption and Assignment of Executory 

Contracts and Unexpired Leases; and (III) Granting Related Relief 

[Docket No. 76]

B. Notice of Possible Assumption and Assignment of Certain Executory 

Contracts and Unexpired Leases in Connection with Sale [Docket 

No. 144] 

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a. Supplemental Notice of Possible Assumption and Assignment of 

Certain Executory Contracts and Unexpired Leases in 

Connection with Sale [Docket No. 460]

C. The Taubman Landlords’ Precautionary Objection to the Notice of 

Possible Assumption and Assignment of Certain Executory 

Contracts and Unexpired Leases, and Cure Claim Objection 

[Docket No. 202] 

D. Limited Objection of Landlord, Palm Beach Mall Holdings LLC, to 

Debtors’ Notice of Possible Assumption and Assignment of Certain 

Executory Contracts and Unexpired Leases in Connection with Sale 

[Docket No. 210]

a. Notice of Withdrawal of Limited Objection of Landlord, Palm 

Beach Mall Holdings LLC [Docket No. 812]

E. Objection and Reservation of Rights of Flow Commerce Inc. to the 

Debtors’ Notice of Possible Assumption and Assignment of Certain 

Executory Contracts and Unexpired Leases in Connection with Sale 

[Docket No. 212] 

F. Objection by Westfield, LLC and Affiliates to Proposed Sale, 

Assumption and Assignment of Unexpired Leases and Proposed 

Cure Amounts [Docket No. 214] 

G. Objection of Bellevue Square, LLC to Debtors’ Notice of Possible 

Assumption and Assignment of Certain Executory Contracts and 

Unexpired Leases in Connection with Sale [Docket No. 222] 

a. Withdrawal of Objection of Bellevue Square, LLC to Debtors’ 

Notice of Possible Assumption and Assignment of Certain 

Executory Contracts and Unexpired Leases in Connection with 

Sale [Docket No. 886] 

H. CBL & Associates Management, Inc. Limited Objection to Debtor’s 

Stated Cure Amounts [Docket No. 223] 

I. Objection of Federal Realty Investment Trust, PGIM Real Estate, 

Retail Properties of America, Inc., Starwood Retail Partners LLC, 

The Forbes Company, The Macerich Company, and TYBAB 

Partners LLC to Debtors’ Notice of Possible Assumption and 

Assignment of Certain Executory Contracts and Unexpired Leases 

in Connection with Sale [Docket No. 230] 

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J. Limited Objection of BP Prucenter Acquisition LLC and OWRF 

Carmel LLC to Notice of Possible Assumption and Assignment of 

Certain Executory Contracts and Unexpired Leases in Connection 

with Sale [Docket No. 231] 

K. Objection of salesforce.com, Inc. to Proposed Assumption and 

Assignment of Certain Executory Contracts and Notice of Cure 

Costs, and Reservation of Rights in Connection with the Pending 

Sale(s) [Docket No. 233] 

L. Objection of Brookfield Property REIT Inc., RREEF Management 

L.L.C., SITE Centers Corp., and Turnberry Associates to Proposed 

Notice of Possible Assumption and Assignment of Certain Executory 

Contracts and Unexpired Leases in Connection with Sale [Docket 

No. 235] 

M. Objection and Reservation of Rights of Washington Prime Group 

Inc. to the Cure Amount Proposed in the Debtors’ Notice of Possible 

Assumption and Assignment of Certain Executory Contracts and 

Unexpired Leases in Connection with Sale [Docket No. 236]

N. Objection and Reservation of Rights of Greater Lakeside LLC to the 

Debtors’ Notice of Possible Assumption and Assignment of Certain 

Executory Contracts and Unexpired Leases in Connection with Sale 

[Docket No. 237]

O. Oracles Limited Objection To And Reservation Of Rights Regarding 

(1) Debtors’ Motion for Entry of Orders (I)(A) Approving Bidding 

Procedures, (B) Approving J&J Stalking Horse Purchase 

Agreement, (C) Scheduling an Auction and Approving Form and 

Manner of Notice Thereof, (D) Approving Assumption and 

Assignment Procedures and (E) Scheduling the Sale Hearing; (II) 

Approving (A) the Sale(s), Free and Clear of Encumbrances and (B) 

Assumption and Assignment of Executory Contracts and Unexpired 

Leases; and (III) Granting Related Relief (“Sale Motion”); and (2) 

Notice of Possible Assumption and Assignment of Certain Executory 

Contracts and Unexpired Leases in Connection with Sale 

(“Assumption Notice”) [Docket No. 238] 

a. Notice of Withdrawal of Oracles Limited Objection To And 

Reservation Of Rights Regarding (1) Debtors’ Motion for Entry 

of Orders (I)(A) Approving Bidding Procedures, (B) Approving 

J&J Stalking Horse Purchase Agreement, (C) Scheduling an 

Auction and Approving Form and Manner of Notice Thereof, 

(D) Approving Assumption and Assignment Procedures and (E) 

Scheduling the Sale Hearing; (II) Approving (A) the Sale(s), 

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Free and Clear of Encumbrances and (B) Assumption and 

Assignment of Executory Contracts and Unexpired Leases; and 

(III) Granting Related Relief (“Sale Motion”); and (2) Notice of 

Possible Assumption and Assignment of Certain Executory 

Contracts and Unexpired Leases in Connection with Sale 

(“Assumption Notice”) [Docket No. 986] 

P. Vestar Green Valley, LLC’s Objection to Proposed Sale, 

Assumption and Assignment of Unexpired Leases and Proposed 

Cure Amounts [Docket No. 239] 

Q. Objection of Teachers Insurance and Annuity Association of 

America to Cure Costs and Proposed Assumption of Unexpired 

Leases [Docket No. 244]

a. Notice of Withdrawal Objection of Teachers Insurance and 

Annuity Associates of America to Cure Costs and Proposed 

Assumption of Unexpired Lease [Docket No. 1002]

R. Limited Objection and Reservation of Rights of Simon Property 

Group, L.P. to Debtors’ Notice of Possible Assumption and 

Assignment of Certain Executory Contracts and Unexpired Leases 

in Connection with Sale [Docket No. 250]

a. Withdrawal of Simon Property Groups, L.P.’s Limited 

Objection to Debtors’ Notice of Possible Assumption and 

Assignment of Certain Executory Contracts and Unexpired 

Leases in Connection with Sale [Docket No. 984]

S. Limited Objection of Landlord, Palm Beach Mall Holdings LLC, to 

Possible Assumption and Assignment of Lease [Docket No. 312] 

a. Notice of Withdrawal of Limited Objection of Landlord, Palm 

Beach Mall Holdings LLC [Docket No. 813] 

T. Aerin LLC Limited Objection to and Reservation of Rights 

Regarding (1) Debtors’ Motion for Entry of Orders (I)(A) 

Approving Bidding Procedures, (B) Approving J&J Stalking Horse 

Purchase Agreement, (C) Scheduling an Auction and Approving 

Form and Manner of Notice Thereof, (D) Approving Assumption 

and Assignment Procedures and (E) Scheduling the Sale Hearing; 

(II) Approving (A) the Sale(s), Free and Clear of Encumbrances and 

(B) Assumption and Assignment of Executory Contracts and 

Unexpired Leases; and (III) Granting Related Relief (“Sale 

Motion”); and (2) Notice of Possible Assumption and Assignment of 

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Certain Executory Contracts and Unexpired Leases in Connection 

with Sale (“Assumption Notice”) [Docket No. 335]

U. Objection of the Chubb Companies to Debtors’ Motion for Entry of 

Orders (I)(A) Approving Bidding Procedures, (B) Approving J&J 

Stalking Horse Purchase Agreement, (C) Scheduling an Auction and 

Approving Form and Manner of Notice thereof, (D) Approving 

Assumption and Assignment Procedures and (E) Scheduling the 

Sale Hearing; (II) Approving (A) the Sale(s), Free and Clear of 

Encumbrances and (B) Assumption and Assignment of Executory 

Contracts and Unexpired Leases; and (III) Granting Related Relief 

[Docket No. 341] 

V. Objection of Federal Realty Investment Trust, PGIM Real Estate, 

Retail Properties of America, Inc., Starwood Retail Partners LLC, 

The Forbes Company, The Macerich Company, and TYBAB 

Partners, LLC to Debtors’ Motion for Entry of Orders (I)(A) 

Approving Bidding Procedures, (B) Approving J&J Stalking Horse 

Purchase Agreement, (C) Scheduling an Auction and Approving 

Form and Manner of Notice thereof, (D) Approving Assumption and 

Assignment Procedures and (E) Scheduling the Sale Hearing; (II) 

Approving (A) the Sale(s), Free and Clear of Encumbrances and (B) 

Assumption and Assignment of Executory Contracts and Unexpired 

Leases; and (III) Granting Related Relief [Docket No. 346] 

W. Limited Objection of Landlord, GFM, LLC to Notice of Possible 

Assumption and Assignment of Certain Executory Contracts and 

Unexpired Leases in Connection with Sale [Docket No. 385]

X. Notice of Auction (Setting the Time to 10:00 AM) [Docket No. 387] 

a. Notice of Adjournment of Auction to Wednesday, February 27, 

2019 at 10:00 A.M. (Prevailing Eastern Time) [Docket No. 409] 

b. Notice of Adjournment of Auction to Thursday, February 28, 

2019 at 10:00 A.M. (Prevailing Eastern Time) [Docket No. 428] 

c. Amended Notice of Adjournment of Auction to Thursday, 

February 28, 2019 at 10:00 A.M. (Prevailing Eastern Time)

[Docket No. 429] 

d. Notice of Adjournment of Auction to Friday, March 1, 2019 at 

9:00 A.M. (Prevailing Eastern Time) and Extension of Adequate 

Assurance Objection Deadline to Monday March 4, 2019 at 

11:00 A.M. (Prevailing Eastern Time) [Docket No. 440] 

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Y. Objection of Brookfield Property REIT Inc., RREEF Management 

L.L.C., SITE Centers Corp. and Turnberry Associates to Proposed 

Assumption and Assignment of Leases [Docket No. 434]

Z. Objection of Landlord, GFM, LLC and Caruso Management Co., 

Ltd., to Possible Assumption and Assignment of Lease and 

Reservation of Rights [Docket No. 452]

AA. Notice of Successful Bidders, Sale Hearing, and Adjournment of the 

Adequate Assurance Objection Deadline [Docket No. 455]

a. Amended Notice of Successful Bidders, Sale Hearing, and 

Adjournment of the Adequate Assurance Objection Deadline 

[Docket No. 457]

BB. Supplemental Declaration of James Doak in Support of Debtors’ 

Motion for Approval of Bidding Procedures, Entry of One or More 

Sale Orders, and Related Relief [Docket No. 463] 

CC. Notice of Adjournment of Cure Objections to Thursday, April 11, 

2019 at 10:00 A.M. (Prevailing Eastern Time) [Docket No. 461]

DD. Notice of Filing of Proposed Sale Orders [Docket No. 472]

EE. Order (I) Approving the Sale of Certain J&J Assets Free and Clear 

of Liens, Claims, Interests and Encumbrances and (II) Approving 

the Assumption and Assignment of Executory Contracts and 

Unexpired Leases in Connection therewith; and (III) Granting 

Related Relief [Docket No. 484]

FF. Order (I) Approving the Sale of Certain Gymboree and Crazy 8 

Assets Free and Clear of Liens, Claims, Interests and 

Encumbrances and (II) Approving the Assumption and Assignment 

of Executory Contracts and Unexpired Leases in Connection 

therewith; and (III) Granting Related Relief [Docket No. 487] 

GG. Notice of Closing Date of J&J Sale [Docket No. 494]

HH. The Taubman Landlords’ Amended Precautionary Objection to the 

Notice of Possible Assumption and Assignment of Certain Executory 

Contracts and Unexpired Leases, and Cure Claim Objection 

[Docket No. 524]

II. Aerin LLC’s Objection to Supplemental Notice of Possible 

Assumption and Assignment of Certain Executory Contracts and 

Unexpired Leases in Connection with Sale [Docket No. 531]

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JJ. Notice of Closing Date of Sale of Gymboree and Crazy 8 Assets to 

TCP Brands, LLC [Docket No. 614]

KK. Notice of Adjournment of Unresolved Cure Objections to 

Wednesday, May 1, 2019 at 1:00 P.M. (Prevailing Eastern Time) 

[Docket No. 631]

LL. Notice of Adjournment of Unresolved Cure Objections to Thursday, 

May 30, 2019 at 1:00 P.M. (prevailing Eastern Time) [Docket No. 

698]

MM. Notice of Adjournment of Unresolved Cure Objections to Thursday, 

May 30, 2019 at 1:00 P.M. (prevailing Eastern Time) [Docket No. 

698]

NN. Notice of Adjournment of Unresolved Cure Objections to Thursday, 

June 20, 2019 at 1:00 P.M. (prevailing Eastern Time) [Docket No. 

771]

OO. Notice of Adjournment of Unresolved Cure Objections to 

Wednesday, July 24, 2019 at 1:00 P.M. (prevailing Eastern Time) 

[Docket No. 817]

PP. Notice of Adjournment of Unresolved Cure Objections to Thursday, 

August 12, 2019 at 1:00 P.M. (prevailing Eastern Time) [Docket 

No. 892]

Status: The Debtors continue to work to reconcile cure amounts with 

counterparties to assumed contracts and leases. Any unresolved 

issues are adjourned to October 16, 2019. 

V. NON-DEBTOR MOTIONS

1. “Pan Pacific Motion.” Notice of and Motion, in Accordance with Agreed Order, to 

Determine that Pan Pacific’s D&O Claims are not Estate Property; and Notice of Hearing 

Thereon [Docket No. 1013] 

Responses Received: None 

Related Documents: 

A. Stipulation and Agreed Order by and among Debtors and Pan 

Pacific Co. Ltd. in Connection with Debtors’ Emergency Motion for 

Interim and Final Orders (I) Enforcing the Automatic Stay, (II) 

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Directing Parties to Comply with Prior Plan, and (III) Granting 

Related Relief [Docket No. 934] 

Status: The parties have agreed to adjourn this matter until the hearing on 

October 16, 2019. 

2. “Aerin Application for Administrative Expenses.” Motion of Aerin LLC for Order (A) 

Directing Payment of Administrative Expense Claim and (B) Compelling Debtors to 

Assume or Reject License Agreement [Docket No. 851] 

Responses Received: 

A. Debtors’ Objection to Motion of Aerin LLC for Order (A) Directing 

Payment of Administrative Expense Claim and (B) Compelling 

Debtors to Assume or Reject License Agreement [Docket No. 935] 

Related Documents: 

A. Notice of Hearing [Docket No. 864]

B. Amended Notice of Hearing [Docket No. 869]

Status: The parties have agreed to adjourn this matter until the hearing on 

October 16, 2019. 

VI. INTERIM FEE APPLICATIONS 

1. “Kutak Interim Fee Application.” Second Interim Application of Kutak Rock LLP, CoCounsel for the Debtors In Possession, for Allowance of Interim Compensation and 

Reimbursement of Expenses Incurred for the Period from April 1, 2019 through June 30, 

2019 [Docket No. 994]. 

Responses Received: None 

Related Documents: 

A. Notice of Hearing and Notice of Application(s) [Docket No. 997] 

Status: This matter is going forward on an uncontested basis. 

2. “Milbank Interim Fee Application.” Second Interim Application of Milbank LLP, CoCounsel for Debtors in Possession, for Allowance of Interim Compensation and 

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Reimbursement of Expenses Incurred from April 1, 2019 through June 30, 2019 [Docket 

No. 1015] 

Responses Received: None 

Related Documents: 

A. Notice of Hearing and Notice of Application [Docket No. 1016] 

Status: This matter is going forward on an uncontested basis. 

3. “Whiteford Interim Fee Application.” Second Interim Application of Whiteford, Taylor 

& Preston, LLP as Co-Counsel to the Official Committee of Unsecured Creditors for 

Compensation and for Reimbursement of Expenses Incurred for the Interim Period from 

April 1, 2019 through June 30, 2019 [Docket No. 1009] 

Responses Received: None 

Related Documents: 

A. Notice of Application and Notice of Hearing [Docket No. 1010] 

Status: This matter is going forward on an uncontested basis. 

4. “Province Interim Fee Application.” First Interim Application of Province, Inc. as 

Financial Advisor to the Official Committee of Unsecured Creditors for Allowance of an 

Administrative Expense Claim for Compensation and for Reimbursement of Expenses 

Incurred for the Period from January 25, 2019 through March 31, 2019 [Docket No. 937] 

Responses Received: None 

Related Documents: 

A. Notice of Fee Hearing [Docket No. 938] 

B. Amended Notice of Fee Hearing [Docket No. 1006] 

Status: This matter is going forward on an uncontested basis. 

5. “Province Interim Fee Application.” Second Interim Application of Province, Inc. as 

Financial Advisor to the Official Committee of Unsecured Creditors for Allowance of an 

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Administrative Expense Claim for Compensation and for Reimbursement of Expenses 

Incurred for the Period from April 1, 2019 through June 30, 2019 [Docket No. 1007] 

Responses Received: None 

Related Documents: 

A. Notice of Application and Notice of Hearing

Status: This matter is going forward on an uncontested basis. 

VII. FINAL FEE STATEMENT

1. “Miller Buckfire Final Fee Application.” Final Fee Application of Miller Buckfire & 

Co., LLC and Stifel, Nicolaus & Co., the Debtors’ Investment Bankers, for Compensation 

for Services Rendered and Reimbursement of Expenses Incurred from the Petition Date 

through the Month of March 2019 [Docket No. 996]. 

Responses Received: None 

Related Documents: 

A. Notice of Hearing and Notice of Application(s) [Docket No. 997] 

Status: This matter is going forward on an uncontested basis. 

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Dated: September 13, 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 1048 Filed 09/13/19 Entered 09/13/19 12:54:29 Desc Main

 Document Page 15 of 15