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 Hill Street Properties LLC

 IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

)

In re: ) Chapter 11 

)

TOYS “R” US PROPERTY COMPANY I, LLC, et al.1

) Case No. 18-31429 (KLP) 

)

Debtors. ) (Jointly Administered) 

)

NOTICE OF HILL STREET PROPERTIES LLC’S SECOND OMNIBUS 

OBJECTION TO CERTAIN (A) REDUCED CLAIMS, (B) INSUFFICIENT 

DOCUMENTATION CLAIMS, (C) SATISFIED LEASE CLAIMS, (D) NO LIABILITY 

CLAIMS, AND (E) SATISFIED TAX CLAIMS 

PLEASE TAKE NOTICE THAT on March 21, 2019, Hill Street Properties LLC (“Hill 

Street”) filed Hill Street Properties LLC’s Second Omnibus Objection to Certain (A) Reduced 

Claims, (B) Insufficient Documentation Claims, (C) Satisfied Lease Claims, (D) No Liability 

Claims, and (E) Satisfied Tax Claims (the “Omnibus Objection”)2 with the Bankruptcy Court. The 

Omnibus Objection is available at https://cases.primeclerk.com/toyspropcoI/ by searching 

“Second Omnibus Objection” in the “Search Docket” field. By the Omnibus Objection, Hill Street 

is seeking to disallow claims, including your claim(s), as set forth on Exhibit A attached hereto, 

because Hill Street alleges your claim(s) either: (i) is in the incorrect amount according to the 

Propco I Debtors’ books and records, (ii) does not contain sufficient documentation to support the 

claim, (iii) is a claim which has previously been satisfied, or (iv) is a claim for which the Propco I 

Debtors do not reflect any liability. 

PLEASE TAKE FURTHER NOTICE THAT on February 28, 2019, the Bankruptcy 

Court entered the Order (I) Approving Procedures for Filing Omnibus Objections to Claims, (II) 

Approving the Form and Manner of the Notice of Omnibus Objections, and (III) Granting Related 

1

 The debtors in these chapter 11 cases, Toys “R” Us Property Company I, LLC. and its debtor affiliates 

(collectively, the “Propco I Debtors”) along with the last four digits of each Propco I Debtor’s federal tax 

identification number, are set forth in the Final Order (I) Directing Joint Administration of Hill Street’ Chapter 

11 Cases and (II) Granting Related Relief [Docket No. 94]. 

2

 Capitalized terms used but not otherwise defined herein shall have the meanings set forth in the Objection. 

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2 

Relief [Docket No. 1267] (the “Order”), approving procedures for filing omnibus objections to 

proofs of claim and requests for allowance and payment of administrative expenses and/or cure 

claims (collectively, the “Claims” and each individually, a “Claim”) in connection with the abovecaptioned chapter 11 cases (the “Omnibus Objection Procedures”). 

YOU ARE RECEIVING THIS NOTICE BECAUSE ALL CLAIMS LISTED HEREIN 

THAT YOU FILED AGAINST ONE OR MORE OF THE PROPCO I DEBTORS IN THE 

ABOVE-CAPTIONED CHAPTER 11 CASES ARE SUBJECT TO THE OMNIBUS 

OBJECTION. YOUR RIGHTS MAY BE AFFECTED BY THE OMNIBUS OBJECTION. 

THEREFORE, YOU SHOULD READ THIS NOTICE (INCLUDING THE OMNIBUS 

OBJECTION AND OTHER ATTACHMENTS) CAREFULLY AND DISCUSS THEM WITH 

YOUR ATTORNEY. IF YOU DO NOT HAVE AN ATTORNEY, YOU MAY WISH TO 

CONSULT ONE. 

MOREOVER, UNDER THE OMNIBUS OBJECTION PROCEDURES, UNLESS A 

WRITTEN RESPONSE AND A REQUEST FOR A HEARING ARE FILED WITH THE CLERK 

OF THE COURT BY 4:00 P.M. (PREVAILING EASTERN TIME) ON APRIL 11, 2019 (THE 

“RESPONSE DEADLINE”) AND SERVED ON THE OBJECTING PARTY, THE COURT 

MAY DEEM ANY OPPOSITION WAIVED, TREAT THE OBJECTION AS CONCEDED, 

AND ENTER AN ORDER GRANTING THE RELIEF REQUESTED WITHOUT A HEARING. 

Critical Information for Claimants 

Choosing to File a Response to the Omnibus Objection 

Who Needs to File a Response: If you oppose the modification or disallowance and 

expungement of your Claim(s) listed below and if you are unable to resolve the Omnibus Objection 

with Hill Street before the deadline to object, then you must file and serve a written response 

(the “Response”) to the Omnibus Objection in accordance with this Notice. 

If you do not oppose the modification or disallowance and expungement of your Claim(s) 

listed below, then you do not need to file a written Response to the Omnibus Objection and you 

do not need to appear at the hearing. 

Response Deadline: The Response Deadline is 4:00 p.m. prevailing Eastern Time on 

April 11, 2019. 

THE BANKRUPTCY COURT WILL ONLY CONSIDER YOUR RESPONSE IF YOUR 

RESPONSE IS FILED BY THE RESPONSE DEADLINE. 

Your Response will be deemed timely filed only if the Response is actually received on 

or before the Response Deadline by the Bankruptcy Court via CM/ECF or at the following address: 

Clerk of the Bankruptcy Court 

United States Bankruptcy Court 

701 East Broad Street 

Richmond, Virginia 23219 

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3 

If the Omnibus Objection is filed by Hill Street, the automatic ECF notification for a timely 

and properly filed Response will satisfy service requirements, and the Response may also be served 

on Hill Street at the following addresses: 

Kutak Rock LLP

Attn: Jeremy S. Williams 

901 East Byrd Street, Suite 1000 

Richmond, Virginia 23219 

Unless otherwise adjourned by the Bankruptcy Court or Hill Street pursuant to the 

Omnibus Objection Procedures, the hearing on the Omnibus Objection and your Response will be 

held at 11:00 a.m. prevailing Eastern Time on April 18, 2019, at: 

United States Bankruptcy Court 

701 East Broad Street – Courtroom 5100 

Richmond, Virginia 23219 

Procedures for Filing a Timely Response 

and Information Regarding the Hearing on the Omnibus Objection 

Contents. Each Response must contain the following (at a minimum): 

1. a caption setting forth the name of the Bankruptcy Court, the name of the Propco I 

Debtor, and the case number and the title of the Omnibus Objection to which the 

Response is directed; 

2. the claimant’s name and an explanation for the amount of the Claim; 

3. a concise statement setting forth the reasons why the Bankruptcy Court should not 

sustain the Omnibus Objection with respect to your Claim(s), including, without 

limitation, the specific factual and legal bases upon which the claimant will rely in 

opposing the Omnibus Objection; 

4. a copy of any other documentation or other evidence of the Claim, to the extent not 

already included with the Claim, upon which the claimant will rely in opposing the 

Omnibus Objection at the hearing; and 

5. your name, address, telephone number and email address and/or the name, address, 

telephone number and email address of your attorney and/or designated 

representative to whom the attorneys for Hill Street should serve a reply to the 

Response, if any (collectively, the “Notice Addresses”). If a Response contains 

Notice Addresses that are different from the name and/or address listed on the 

Claim, the Notice Addresses will control and will become the service address for 

future service of papers with respect to all of your Claims listed in the Omnibus 

Objection (including all Claims to be modified or disallowed and expunged and the 

surviving claims) and only for those Claims in the Omnibus Objection. 

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4 

Additional Information. To facilitate a resolution of the Omnibus Objection, your 

Response should also include the name, address, telephone number, and email address of the party 

with authority to reconcile, settle or otherwise resolve the Omnibus Objection on the claimant’s 

behalf (the “Additional Addresses”). Unless the Additional Addresses are the same as the Notice 

Addresses, the Additional Addresses will not become the service address for future service of 

papers. 

Failure to File Your Timely Response. If you fail to file your Response on or before the 

Response Deadline in compliance with the procedures set forth in this Notice and timely serve it 

on Hill Street, Hill Street will present to the Bankruptcy Court an appropriate order granting the 

relief requested in the Omnibus Objection without further notice to you. 

Hearing Attendance. If you file a Response to the Omnibus Objection, then you should 

plan to appear at the hearing on the Omnibus Objection. Hill Street, however, reserves the right 

to continue the hearing with respect to the Omnibus Objection and the Response. 

Rescheduling the Hearing. If the Bankruptcy Court determines that the hearing on the 

Omnibus Objection will require substantial time for the presentation of argument and/or evidence, 

then the Bankruptcy Court, in its discretion, may reschedule the hearing. 

Each Objection Is a Contested Matter. Each Claim subject to an Omnibus Objection and 

the Response thereto shall constitute a separate contested matter as contemplated by Bankruptcy 

Rule 9014, and any order entered by the Bankruptcy Court will be deemed a separate order with 

respect to such Claim. 

Additional Information 

Reply of Hill Street. Hill Street may file a reply to your Response or reply in oral argument 

at the hearing. In such event, Hill Street is permitted to file its reply no later than one calendar day 

before the hearing on the Omnibus Objection and the Response. 

Additional Discovery. Upon receipt of your Response, Hill Street may determine that 

discovery is necessary in advance of the hearing on the Omnibus Objection and your Response. 

In such event, Hill Street will serve separate notice to the Notice Addresses that the scheduled 

hearing will be treated as a status conference during which the parties will request that the 

Bankruptcy Court issue a scheduling order to facilitate resolution of the Response. 

Notwithstanding the foregoing, nothing herein modifies any parties’ right to seek discovery or 

request that the scheduled hearing be treated as a status conference. 

Requests for Information. If you have any questions regarding the Omnibus Objection 

and/or if you wish to obtain a copy of the Omnibus Objection or related documents, you may call 

the Debtors’ restructuring hotline at (844) 794-3476. You may also obtain a copy of the Omnibus 

Objection or related documents by visiting the Propco I Debtors’ restructuring website at 

https://cases.primeclerk.com/toyspropcoI/. 

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5 

Reservation of Rights. Nothing in this Notice or the Omnibus Objection constitutes a 

waiver of Hill Street’s right to assert any claims, counterclaims, rights of offset or recoupment, 

preference actions, fraudulent-transfer actions, or any other claims against the claimant of the 

Propco I Debtors. Unless the Bankruptcy Court allows your Claims or specifically orders 

otherwise, the Hill Street has the right to object on any grounds to the Claims (or to any other 

Claims or causes of action you may have filed or that have been scheduled by the Propco I Debtors) 

at a later date. In such event, you will receive a separate notice of any such objections. 

[Remainder of page intentionally left blank]

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Richmond, Virginia 

Dated: March 21, 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 Hill Street Properties LLC

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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 Hill Street Properties LLC

 IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

)

In re: ) Chapter 11 

)

TOYS “R” US PROPERTY COMPANY I, LLC, et al.1

) Case No. 18-31429 (KLP) 

)

Debtors. ) (Jointly Administered) 

)

HILL STREET PROPERTIES LLC’S 

SECOND OMNIBUS OBJECTION TO CERTAIN (A) REDUCED CLAIMS, 

(B) INSUFFICIENT DOCUMENTATION CLAIMS, (C) SATISFIED LEASE CLAIMS, 

(D) NO LIABILITY CLAIMS, AND (E) SATISFIED TAX CLAIMS 

THIS OBJECTION SEEKS TO MODIFY OR DISALLOW AND EXPUNGE CERTAIN FILED 

PROOFS OF CLAIM. CLAIMANTS RECEIVING THIS OBJECTION SHOULD LOCATE 

THEIR NAMES AND CLAIMS ON SCHEDULES 1-5 TO 

 EXHIBIT A ATTACHED TO THIS OBJECTION. 

Hill Street Properties LLC (“Hill Street”) files this omnibus objection (this “Objection”) 

and seeks entry of an order, substantially in the form attached hereto as Exhibit A (the “Order”): 

• modifying the claims identified on Schedule 1 to the Order (collectively, the 

“Reduced Amount Claims”) because such claims were filed in the incorrect 

amount based on the Propco I Debtors’ books and records; 

• disallowing and expunging the claims identified on Schedule 2 to the Order 

(collectively, the “Insufficient Documentation Claims”) in their entirety because 

1

 The debtors in these chapter 11 cases, Toys “R” Us Property Company I, LLC. and its debtor affiliates 

(collectively, the “Propco I Debtors”) along with the last four digits of each Propco I Debtor’s federal tax 

identification number, are set forth in the Final Order (I) Directing Joint Administration of Hill Street’ Chapter 

11 Cases and (II) Granting Related Relief [Docket No. 94]. 

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2 

such claims fail to specify sufficiently the basis for the claim or provide sufficient 

supporting documentation; 

• disallowing and expunging the claims identified on Schedule 3 to the Order 

(collectively, the “Satisfied Lease Claims”) in their entirety because, based on the 

Propco I Debtors’ books and records, such lease claims have been paid or 

otherwise settled and the Propco I Debtors no longer have any outstanding liability 

associated therewith; 

• disallowing and expunging the claims identified on Schedule 4 to the Order 

(collectively, the “No Liability Claims”) in their entirety because based on the 

Propco I Debtors’ books and records, the Propco I Debtors have no liability for 

such claims; and 

• disallowing and expunging the claims identified on Schedule 5 to the Order 

(collectively, the “Satisfied Tax Claims” and together with the Reduced Amount 

Claims, the Insufficient Documentation Claims, the Satisfied Lease Claims and the 

No Liability Claims, the “Disputed Claims”) in their entirety because, based on the 

Propco I Debtors’ books and records, such tax claims have been paid or otherwise 

settled and the Propco I Debtors no longer have any outstanding liability associated 

therewith. 

In support of this Objection, Hill Street submits the Declaration of Michael Atkinson in 

Support of Hill Street Properties LLC’s Second Omnibus Objection to Certain (A) Reduced 

Claims, (B) Insufficient Documentation Claims, (C) Satisfied Lease Claims, (D) No Liability 

Claims, and (E) Satisfied Tax Claims (the “Atkinson Declaration”), attached to this Objection as 

Exhibit B, and respectfully state as follows. 

Jurisdiction 

1. The United States Bankruptcy Court for the Eastern District of Virginia 

(the “Court”) has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the 

Standing Order of Reference from the United States District Court for the Eastern District of 

Virginia, dated July 10, 1984. Hill Street confirm their consent, pursuant to Rule 7008 of the 

Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), to the entry of a final order by 

the Court in connection with this Motion to the extent that it is later determined that the Court, 

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3 

absent consent of the parties, cannot enter final orders or judgments in connection herewith 

consistent with Article III of the United States Constitution. 

2. The bases for the relief requested herein are sections 502 and 1106(a)(1) of title 11 

of the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), Bankruptcy 

Rules 3007 and 9014, and Rule 3007–1 of the Local Bankruptcy Rules for the United States 

Bankruptcy Court for the Eastern District of Virginia (the “Local Rules”). 

Relief Requested 

3. By this Objection, Hill Street respectfully requests entry of an order (a) modifying 

or disallowing and expunging the Disputed Claims identified on Schedules 1-5 to the Order, as 

applicable, and (b) granting related relief. 

Background 

4. On March 20, 2018 (the “Petition Date”), the Propco I Debtors each filed a 

voluntary petition for relief under chapter 11 of the Bankruptcy Code. The Propco I Debtors are 

operating their businesses and managing their properties as debtors in possession pursuant to 

sections 1107(a) and 1108 of the Bankruptcy Code. A detailed description surrounding the facts 

and circumstances of these chapter 11 cases is set forth in the Declaration of David A. Brandon, 

Chairman of the Board and Chief Executive Officer of Toys R Us, Inc., in Support of Chapter 11 

Petitions and First Day Motions [Case No. 17-34665; Docket No. 20] and the Declaration of 

Michael J. Short, Chief Financial Officer of Toys “R” Us, Inc., in Support of Debtors’ First Day 

Motions [Case No. 17-34665; Docket No. 30]. On May 17, 2018, the Propco I Debtors filed their 

schedules of assets and liabilities and statements of financial affairs [Docket Nos. 137-139 and 

142] (collectively, the “Schedules”). 

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4 

The Claims Reconciliation Process 

5. On October 12, 2018, this Court entered the Order (I) Setting Bar Dates for Filing 

Proofs of Claim, Including Requests for Payment Under Section 503(b)(9), (II) Establishing 

Amended Schedules Bar Date and Rejection Damages Bar Date, (III) Approving the Form of and 

Manner For Filing Proofs of Claim, Including Section 503(b)(9) Requests, (IV) Approving Notice 

of Bar Dates, and (V) Granting Related Relief [Docket No. 642] (the “Claims Bar Date Order”), 

which, among other things, established the following deadlines for filing proofs of prepetition 

claim (collectively, the “Bar Dates”): (a) November 12, 2018, at 5:00 p.m., prevailing Eastern 

Time as the deadline by which all claimants holding claims arising prior to the Petition Date, 

including claims arising under 11 U.S.C. § 503(b)(9), were required to file their proofs of claim in 

the Propco I Debtors’ chapter 11 cases, unless otherwise set forth therein; and (b) with respect to 

claims arising from the rejection of executory contracts and unexpired leases of the Propco I 

Debtors, the later of (i) November 12, 2018, and (ii) 5:00 p.m., prevailing Eastern time, on the date 

that is 30 days following entry of an order approving the rejection of any executory contract or 

unexpired lease of the Propco I Debtors. 

6. On March 23, 2018, the Bankruptcy Court entered the Order (I) Granting Limited 

Application of the Relief Requested Under the Toys "R" Us Debtors' Omnibus Wind-Down Motion 

and (II) Granting Related Relief [Docket No. 20] pursuant to which the Court authorized the 

Propco I Debtors to begin to wind down their U.S. operations. 

7. On December 22, 2018, the Propco I Debtors filed the Fourth Amended Joint 

Chapter 11 Plan of Toys “R” Us Property Company I, LLC and Its Debtor Affiliates [Docket No. 

1101] (as may be modified, amended, or supplemented from time to time, the “Plan”), which Plan 

was confirmed on March 5, 2019 [Docket No. 1280]. Pursuant to the Plan, creditors asserting 

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5 

claims for costs and expenses of administration of the Propco I Debtors’ estates pursuant to 

sections 328, 330, 503(b) or 507(a)(2) of the Bankruptcy Code, including the actual and necessary 

costs and expenses of preserving the estates and operating the business of the Propco I Debtors 

incurred after the Petition Date and through and including the Effective Date (as defined in the 

Plan) (collectively, the “Admin Claims”), are required to filed their Admin Claims on or before 

April 8, 2019. 

8. Written notice of the Bar Dates was mailed to, among others, all known creditors 

and other known holders of claims against the Propco I Debtors, identified as of the date of entry 

of the Claims Bar Date Order, including all entities listed in the Schedules as holding claims 

against the Propco I Debtors, and to all parties who had filed requests for notices under Bankruptcy 

Rule 2002 as of the date of the Bar Date Orders. In addition to mailing such actual notice, the 

Propco I Debtors also published notice of the Bar Dates in USA Today (national edition) and the

Wall Street Journal (national edition).

9. On February 28, 2018, the Court entered the Order (I) Approving Procedures for 

Filing Omnibus Objections to Claims, (II) Approving the Form and Manner of the Notice of 

Omnibus Objections, and (III) Granting Related Relief [Docket No. 1267] approving the Propco I 

Debtor’s proposed objection procedures (the “Objection Procedures”). This Objection is filed in 

accordance with the Objection Procedures. 

10. On March 5, 2019, the Court confirmed the Plan pursuant to the Order Confirming 

the Fourth Amended Joint Chapter 11 Plan of Toys “R” Us Property Company I, LLC and Its 

Debtor Affiliates [Docket No. 1280]. The Effective Date (as defined in the Plan) occurred on 

March 8, 2019 [Docket No. 1297]. Pursuant to the Plan and for the limited purposes set forth 

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6 

therein, Hill Street is the successor to the Debtors, including with respect to the reconciliation of 

outstanding proofs of claim. 

11. To date, approximately 710 proofs of claim (collectively, “Proofs of Claim” and 

individually, a “Proof of Claim”) have been filed against the Propco I Debtors, including 

approximately 261 proofs of claim seeking payment of administrative, secured and/or priority 

expenses. Hill Street and their advisors are in the process of reviewing the Proofs of Claim, 

including supporting documentation, if any, filed with the Proofs of Claim, and reconciling the 

Proofs of Claim with the Propco I Debtors’ books and records to determine the validity of the 

Proofs of Claim. For the reasons set forth in more detail below, and based on their review to date, 

Hill Street has determined that the Disputed Claims are objectionable on the grounds set forth 

below. 

Objection 

I. Reduced Amount Claims 

12. Hill Street objects to the Reduced Amount Claims set forth on Schedule 1 to the 

Order. Based on their review of the Proofs of Claim, Hill Street has determined that the Reduced 

Amount Claims, as filed, do not accurately reflect amounts owed by the Propco I Debtors 

according to their books and records. Instead, Hill Street believes that the asserted amount of such 

claims as identified in the column titled “Claim” should be modified to the amounts in the column 

titled “Modified Claim” in the table provided in Schedule 1 to the Order. Hill Street asserts that 

the amount listed in the “Modified Claim” column for each Reduced Amount Claim represents the 

fair, accurate, and reasonable value of each respective Proof of Claim, as reflected in the Propco I 

Debtors’ books and records and/or from the information provided by the claimants. Failure to 

modify such claims could result in the relevant claimants receiving a better recovery than other 

similarly situated creditors, even though such recovery is not warranted. Accordingly, Hill Street 

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7 

requests that the Court enter the Order, modifying the Reduced Amount Claims identified on 

Schedule 1 to the Order. 

II. Insufficient Documentation Claims 

13. Hill Street objects to the Insufficient Documentation Claims identified on 

Schedule 2 to the Order. Based on its review of the Proofs of Claim filed in these chapter 11 

cases, the Insufficient Documentation Claims do not include sufficient information to enable Hill 

Street to reconcile these Proofs of Claim with their books and records. 

14. A proof of claim must “set forth the facts necessary to support the claim.” In re 

Chain, 255 B.R. 278, 280 (Bankr. D. Conn. 2000) (citing 9, Resnick & Sommer eds., Collier on 

Bankruptcy ¶ 3001.09[1] at 3001-27 (15th ed. rev. 2005)) (emphasis added). If the proof of claim 

fails to set forth the necessary supporting facts, it is “not entitled to the presumption of prima facie 

validity, and the burdens of going forward and of proving its claims by a preponderance of the 

evidence are on the [claimant].” In the Matter of Marino, 90 B.R. 25, 28 (Bankr. D. Conn. 1988); 

see also In re Svendson, 34 B.R. 341, 342 (Bankr. D.R.I. 1983) (stating proofs of claim failed to 

“set forth all the necessary facts to establish the claim[s].”). 

15. Without providing sufficient information or documentation to allow Hill Street to 

reconcile the Insufficient Documentation Claims with their books and records, the Insufficient 

Documentation Claims fail to satisfy the requirements for a proof of claim. See Chain, 255 B.R. 

at 280. See also In re 20/20 Sport, Inc., 200 B.R. 972, 978 (Bankr. S.D.N.Y 1996) (“In bankruptcy 

cases, courts have traditionally analogized a creditor’s claim to a civil complaint, [and] a trustee’s 

objection to an answer . . . .”). 

16. Moreover, the Propco I Debtors’ estates should not be required to pay a purported 

creditor to the detriment of a proven creditor. The elimination of Insufficient Documentation 

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8 

Claims will streamline the claims reconciliation process and enable the Debtors to maintain a more 

accurate claims register. Accordingly, Hill Street hereby requests that the Court enter an order 

expunging and disallowing the Insufficient Documentation Claims identified on Schedule 2 of the 

Order. 

III. Satisfied Lease Claims 

17. Hill Street objects to the Satisfied Lease Claims set forth on Schedule 3 to the 

Order. Based on their review of the Proofs of Claim and a thorough analysis of the Propco I 

Debtors’ books and records, Hill Street has determined that the obligations related to such Satisfied 

Lease Claims have been paid or otherwise settled and the Propco I Debtors no longer have any 

outstanding liabilities associated therewith. As a result, Hill Street is seeking an order expunging 

and disallowing the Satisfied Lease Claims, as identified on Schedule 3 to the Order. Failure to 

disallow and expunge the Satisfied Lease Claims could result in the applicable claimants receiving 

multiple recoveries against the Propco I Debtors’ estates, to the detriment of other similarly 

situated creditors. Moreover, elimination of the Satisfied Lease Claims will enable Hill Street to 

maintain a more accurate claims register. Accordingly, Hill Street requests that the Court enter 

the Order, disallowing and expunging the Satisfied Lease Claims identified on Schedule 3 to the 

Order. 

IV. No Liability Claims 

18. Hill Street objects to the No Liability Claims set forth on Schedule 4 to the Order. 

Based on their review of the Proofs of Claim and a thorough analysis of the Propco I Debtors’ 

books and records, Hill Street has determined that the No Liability Claims, as filed, do not 

accurately reflect amounts owed by the Propco I Debtors according to their books and records. 

Instead, the Propco I Debtors assert that they have no liability for such Proofs of Claim. 

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9 

19. For the reasons set forth above, Hill Street is seeking an order expunging and 

disallowing the No Liability Claims, as identified on Schedule 4 to the Order. Failure to disallow 

and expunge the No Liability Claims could result in the applicable claimants receiving multiple 

recoveries against the Propco I Debtors’ estates, to the detriment of other similarly situated 

creditors. Moreover, elimination of the No Liability Claims will enable Hill Street to maintain a 

more accurate claims register. Accordingly, Hill Street requests that the Court enter the Order, 

disallowing and expunging the No Liability Claims identified on Schedule 4 to the Order. 

V. Satisfied Tax Claims 

20. Hill Street objects to the Satisfied Tax Claims set forth on Schedule 5 to the Order. 

Based on their review of the Proofs of Claim and a thorough analysis of the Propco I Debtors’ 

books and records, Hill Street has determined that the obligations related to such Satisfied Tax 

Claims have been paid or otherwise settled and the Propco I Debtors no longer have any 

outstanding liabilities associated therewith. As a result, Hill Street is seeking an order expunging 

and disallowing the Satisfied Tax Claims, as identified on Schedule 5 to the Order. Failure to 

disallow and expunge the Satisfied Tax Claims could result in the applicable claimants receiving 

multiple recoveries against the Propco I Debtors’ estates, to the detriment of other similarly 

situated creditors. Moreover, elimination of the Satisfied Tax Claims will enable Hill Street to 

maintain a more accurate claims register. Accordingly, Hill Street requests that the Court enter 

the Order, disallowing and expunging the Satisfied Lease Claims identified on Schedule 5 to the 

Order. 

Basis for Relief 

21. Section 502(a) of the Bankruptcy Code provides that “[a] claim or interest, proof 

of which is filed under section 501 of this title, is deemed allowed, unless a party in interest . . . 

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10 

objects.” A debtor in possession has the duty to object to the allowance of any claim that is 

improper. See 11 U.S.C. § 1106(a)(1). 

22. As set forth in Bankruptcy Rule 3001(f), a properly executed and filed proof of 

claim constitutes prima facie evidence of the validity and the amount of the claim under 

section 502(a) of the Bankruptcy Code. See In re Allegheny Int’l, Inc., 954 F.2d 167, 173 (3d Cir. 

1992). Bankruptcy courts have generally held that in order to receive the benefit of prima facie

validity, however, the claimant must set forth facts necessary to support the claim. See In re 

McCarthy, No. 04-10493, 2004 WL 5683383, at *5 (Bankr. E.D. Va. July 14, 2004). Additionally, 

a claimant’s proof of claim is entitled to the presumption of prima facie validity under Bankruptcy 

Rule 3001(f) only until an objecting party shows that there exists a “true dispute” as to the validity 

and amount of the claim. See In re Computer Learning Ctrs., Inc., 298 B.R. 569, 578 (Bankr. E.D. 

Va. 2003) (quoting Collier on Bankruptcy ¶ 3001.09[2] (15th ed. revised 2003)). Once the 

objecting party refutes an allegation critical to the claim, the burden reverts to the claimant to prove 

the validity of the claim by a preponderance of the evidence. Allegheny, 954 F.2d at 173. In other 

words, once the prima facie validity of a claim is rebutted, “it is for the claimant to prove his claim, 

not for the objector to disprove it.” In re Kahn, 114 B.R. 40, 44 (Bankr. S.D.N.Y. 1990) (citations 

omitted). 

23. For the reasons set forth in this Objection and in the Atkinson Declaration, the Court 

should modify or disallow and expunge the Disputed Claims as requested in herein. If the Disputed 

Claims are not formally modified or disallowed and expunged, the potential exists for the 

applicable claimants to receive recoveries to which they are not entitled, to the detriment of the 

Propco I Debtors’ other stakeholders and the process of claims administration and reconciliation 

will be unnecessarily burdensome. Thus, the relief requested in this Objection is necessary to 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

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11 

prevent any inappropriate distribution of estate funds and to facilitate the administration of the 

claims-allowance process. 

Separate Contested Matter 

24. Each of the above objections to the proofs of claim constitutes a separate contested 

matter as contemplated by Bankruptcy Rule 9014. Hill Street requests that any order entered by 

the Court with respect to an objection asserted herein will be deemed a separate order with respect 

to each Claim. 

Responses to Omnibus Objections 

25. To contest this Objection, a claimant must file and serve a written response to this 

Objection in accordance with the Objection Procedures. If a claimant fails to file and serve a 

response in accordance with the Objection Procedures, Hill Street may present to the Court an 

appropriate order disallowing the Disputed Claim, without further notice to the claimant or a 

hearing. 

Reservation of Rights 

26. Nothing contained herein is intended or shall be construed as: (a) an admission as 

to the amount of, basis for, or validity of any claim against the Propco I Debtors under the 

Bankruptcy Code or other applicable non-bankruptcy law; (b) a waiver of Hill Street’s or any other 

party in interest’s right to dispute any claim; (c) a promise or requirement to pay any particular 

claim; (d) an implication or admission that any particular claim is of a type specified or defined in 

this motion; (e) an admission as to the validity, priority, enforceability, or perfection of any lien 

on, security interest in, or other encumbrance on property of the Propco I Debtors’ estates; or (f) a 

waiver of any claims or causes of action which may exist against any entity under the Bankruptcy 

Code or any other applicable law. 

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12 

Notice 

27. Hill Street will provide notice of this Motion via first class mail and email (where 

available) to: (a) the Office of the United States Trustee for the Eastern District of Virginia, Attn: 

Robert B. Van Arsdale and Lynn A. Kohen; (b) the Official Committee of Unsecured Creditors;; 

(c) the administrative agent for the prepetition Secured Term Loan B Facility and the advisors and 

counsel thereto; (d) the prepetition administrative agent for the Propco I Unsecured Term Loan 

Facility and the advisors and counsel thereto; (e) counsel to the ad hoc group of the Term B-4 

Holders; (f) the ad hoc group of lenders (the “Ad Hoc Group of Propco I Lenders”) under that 

certain Credit Agreement, dated as of August 21, 2013 (the “Propco I Credit Agreement”); (g) 

Strategic Asset Services, LLC as a lender under the Propco I Credit Agreement; (h) Akin Gump 

Strauss Hauer & Feld LLP as counsel to Strategic Asset Services, LLC; (i) the Internal Revenue 

Service; (j) the office of the attorneys general for the states in which Hill Street operate; (k) the 

Securities and Exchange Commission; (l) any party that has requested notice pursuant to 

Bankruptcy Rule 2002; and (m) holders of the Disputed Claims identified on Schedules 1-5 to the 

Order. Hill Street submits that, in light of the nature of the relief requested, no other or further 

notice need be given. 

No Prior Request 

28. No prior request for the relief sought in this Objection has been made to this or any 

other court. 

WHEREFORE, Hill Street respectfully request that the Court enter the Order granting the 

relief requested herein and such other relief as the Court deems appropriate under the 

circumstances. 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 18 of 66
13 

Richmond, Virginia 

Dated: March 21, 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 Hill Street Properties LLC

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

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Exhibit A 

Proposed Form of Order

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

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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 Hill Street Properties LLC

 IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

)

In re: ) Chapter 11 

)

TOYS “R” US PROPERTY COMPANY I, LLC, et al.1

) Case No. 18-31429 (KLP) 

)

Debtors. ) (Jointly Administered) 

)

ORDER GRANTING HILL STREET PROPERTIES LLC’S SECOND OMNIBUS 

OBJECTION TO CERTAIN (A) REDUCED CLAIMS, (B) INSUFFICIENT 

DOCUMENTATION CLAIMS, (C) SATISFIED LEASE CLAIMS, (D) NO LIABILITY 

CLAIMS, AND (E) SATISFIED TAX CLAIMS 

Upon the omnibus objection (the “Objection”)2of Hill Street Properties LLC for entry of 

an order (this “Order”): (a) modifying or disallowing and expunging the Disputed Claims 

identified on Schedules 1-5 attached hereto, in accordance with section 502 of the Bankruptcy 

Code, Bankruptcy Rule 3007, and Local Rule 3007–1; and (b) granting related relief, all as more 

fully set forth in the Objection; and it appearing that the relief requested is in the best interests of 

the Propco I Debtors’ estates, their creditors and other parties in interest; and the Court having 

jurisdiction to consider the Objection and the relief requested therein pursuant to 28 U.S.C. §§ 157 

1

 The debtors in these chapter 11 cases, Toys “R” Us Property Company I, LLC. and its debtor affiliates 

(collectively, the “Propco I Debtors”) along with the last four digits of each Propco I Debtor’s federal tax 

identification number, are set forth in the Final Order (I) Directing Joint Administration of Hill Street’ Chapter 

11 Cases and (II) Granting Related Relief [Docket No. 94]. 

2 Capitalized terms used but not otherwise defined in this Order have the meanings given to them in the Objection. 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 21 of 66
2 

and 1334; and consideration of the Objection and the relief requested therein being a core 

proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper before this Court pursuant to 

28 U.S.C. §§ 1408 and 1409; and notice of the Objection having been adequate and appropriate 

under the circumstances; and after due deliberation and sufficient cause appearing therefor, it is 

HEREBY ORDERED:

1. The Objection is granted as set forth in this Order. 

2. Any response to the Objection not otherwise withdrawn, resolved, or adjourned is 

hereby overruled on its merits. 

3. Each Reduced Amount Claim, as identified on Schedule 1 to this Order, is modified 

to the amount identified in the column titled “Modified Claim” in Schedule 1 to this Order; 

provided, that Hill Street maintains the right to object to any Proof of Claim identified in the 

“Modified Claim” column on Schedule 1 on any applicable grounds. 

4. Each Insufficient Documentation Claim identified on Schedule 2 attached to this 

Order is disallowed and expunged in its entirety. 

5. Each Satisfied Lease Claim identified on Schedule 3 attached to this Order is 

disallowed and expunged in its entirety. 

6. Each No Liability Claim identified on Schedule 4 attached to this Order is 

disallowed and expunged in its entirety. 

7. Each Satisfied Tax Claim identified on Schedule 5 attached to this Order is 

disallowed and expunged in its entirety. 

8. Prime Clerk LLC, Hill Street’s notice and claims agent, is directed to update the 

claims register to reflect the relief granted in this Order. 

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3 

9. Except as provided in this Order, nothing in this Order will be deemed (a) an 

admission or finding as to the validity of any Proof of Claim against a Propco I Debtor entity, (b) 

a waiver of the right of Hill Street to dispute any Proof of Claim against any Propco I Debtor on 

any grounds whatsoever, at a later date, (c) a promise by or requirement on any Propco I Debtor 

to pay any Proof of Claim, (d) an implication or admission that any particular Proof of Claim is of 

a type specified or defined in this Order, or (e) a waiver of the rights of Hill Street under the 

Bankruptcy Code or any other applicable law. 

10. Each of the Disputed Claims and the objections by Hill Street to each of the 

Disputed Claims, as addressed in the Objection and set forth on Schedules 1-5, each attached to 

this Order, constitute a separate contested matter as contemplated by Bankruptcy Rule 9014. This 

Order will be deemed a separate Order with respect to each Disputed Claim. Any stay of this 

Order pending appeal by any claimants whose Proofs of Clam are subject to this Order will only 

apply to the contested matter that involves such claimant and will not act to stay the applicability 

or finality of this Order with respect to the other contested matters identified in the Objection or 

this Order. 

11. Hill Street is authorized to take all actions necessary to effectuate the relief granted 

pursuant to this Order in accordance with the Objection. 

12. This Court retains exclusive jurisdiction with respect to all matters arising from or 

related to the implementation of this Order. 

Dated: ______________ 

Richmond, Virginia THE HONORABLE KEITH L. PHILLIPS 

UNITED STATES BANKRUPTCY JUDGE 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

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WE ASK FOR THIS: 

/s/ Jeremy S. Williams

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 Hill Street Properties LLC 

CERTIFICATION OF ENDORSEMENT 

UNDER LOCAL BANKRUPTCY RULE 9022-1(C) 

Pursuant to Local Bankruptcy Rule 9022-1(C), I hereby certify that the foregoing 

proposed order has been endorsed by or served upon all necessary parties. 

 /s/ Jeremy S. Williams

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

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Schedule 1 

Reduced Amount Claims

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

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Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

A&W ACQUISITIONS, LLC 404 10/23/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Rejection damages estimated at $95,733 

per debtor's records for remaining lease 

period ending 1/31/19; prorated October 

2018 rent and CAM fees paid by debtor, 

check #7732973.

$2,404.44

$230,425.02

A

U

$0.00

$95,733.04

A

U

DAVID M. BLAU, ESQ. 151 S. OLD 

WOODWARD AVE., STE. 200

BIRMINGHAM, MI 48009

ALISUE LLC AND DIAJEFF LLC 584 11/16/2018 TRU 2005 RE I, LLC

18-31431

Estimated rejection damages per debtor's 

records for one year of rent, CAM, and 

taxes is $171,526; one-year rejection 

damages per creditor total $259,449, and 

also included in the claim are $499,279 in 

estimated repair, maintenance, and other 

fees.

$758,727.95 U $171,525.57 U

C/O KIN PROPERTIES, INC 185 NW 

SPANISH RIVER BLVD, SUITE 100

BOCA RATON, FL 33431

AURSAN COMPANY LLC 435 10/31/2018 TRU 2005 RE I, LLC

18-31431

Estimated rejection damages per debtor's 

records for one year of rent, CAM, and 

taxes is $284,319; one-year rejection 

damages per creditor total $353,399, and 

also included in the claim are $13,285 in 

estimated repair, maintenance, and other 

fees.

$366,684.29 U $284,319.45 U

C/O MICHAEL BEST & FRIEDRICH LLP 

ATTN: JONATHAN GOLD 601 

PENNSYLVANIA AVENUE NW SUITE 700 

SOUTH

WASHINGTON, DC 20004

BALI PROPERTIES, INC. 551 11/12/2018 TRU 2005 RE I, LLC

18-31431

Creditor rejection damages of $693,000 

similar to debtor's estimated amount; 

remainder of claim is for $46,700 in 

estimated costs to clean and secure 

building.

$739,700.00 U $693,000.00 U

C/O WILLIAM C. BECK, JR. P.O. BOX 241

JEFFERSON VALLEY, NY 10535

BERWICK-KRAUSZ 542 11/12/2018 TRU 2005 RE I, LLC

18-31431

Rejection damages estimated at $340,437 

plus $6,082.32 for unpaid CAM charges 

per debtor's books and records; no postpetition amounts due per debtor.

$9,310.84

$530,489.61

A

U

$0.00

$346,519.71

A

U

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ. 2029 CENTURY PARK 

EAST, SUITE 800

LOS ANGELES, CA 90067-2909

BEST BUY STORES, L.P. 474 11/8/2018 TRU 2005 RE I, LLC

18-31431

Amount due per debtor's books and 

records is $99,057; no basis for priority 

portion of claim.

$2,850.00

$103,699.80

P

U

$0.00

$99,057.00

P

U

ATTN: LEGAL DEPARTMENT - REAL 

ESTATE 7601 PENN AVENUE SOUTH

RICHFIELD, MN 55423

Page 1 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 26 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

CHERRY HILL UE LLC 529 11/12/2018 TRU 2005 RE I, LLC

18-31431

Estimated rejection damages per debtor's 

records are $833,243.

$865,782.81 U $833,242.70 U

C/O URBAN EDGE PROPERTIES ATTN: MEI 

CHENG 210 ROUTE 4 EAST

PARAMUS, NJ 07652

CITY OF WARNER ROBINS 339 6/29/2018 Toys "R" Us Property 

Company I, LLC

18-31429

No amounts due per debtor's books and 

records.

$3,794.39 U $0.00 U

JIM ELLIOT PO BOX 8629

WARNER ROBINS, GA 31095

CLIFFORD ENTITIES, LLC 615 7/16/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$20,667.09 A $0.00 A

SPOKANE VALLEY PLAZA 818 W 

RIVERSIDE AVE STE 660

SPOKANE, WA 99201

DANIEL G. KAMIN LIMA ENTERPRISES 296 7/16/2018 MAP Real Estate, LLC

18-31430

Agree with rejection damages; no other 

pre-petition amounts due per debtor's 

books and records.

$346,241.46 U $294,144.50 U

KEPLEY BROSCIOUS & BIGGS, PLC. 

WILLIAM A. BROCIOUS, ESQ. 2211 PUMP 

ROAD

RICHMOND, VA 23233

DG RETAIL LEASECO, L.L.C. 465 11/7/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$115,375.73 A $0.00 A

C/O BARCLAY DAMON LLP ATTN: KEVIN 

M. NEWMAN BARCLAY DAMON TOWER 

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

DG RETAIL LEASECO, L.L.C. 463 11/7/2018 TRU 2005 RE I, LLC

18-31431

Rejection damages calculated at 

$157,045 per debtor's books and records.

$174,669.56 U $157,045.22 U

C/O BARCLAY DAMON LLP ATTN: KEVIN 

M. NEWMAN BARCLAY DAMON TOWER 

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

EVERETT MALL 01, LLC 533 11/12/2018 Toys "R" Us Property 

Company I, LLC

18-31429

No amounts due per debtor's books and 

records.

$2,938.76 U $0.00 U

MOYE WHITE LLP TIMOTHY M. 

SWANSON 1400 16TH ST., 6TH FLR.

DENVER, CO 80202

Page 2 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

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 Document Page 27 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

FAIR LAKES LEAGUE, INC. 552 11/12/2018 Toys "R" Us Property 

Company I, LLC

18-31429

No balance due per debtor's books and 

records.

$3,076.32 U $0.00 U

ANDREW SCHULWOLF, ESQ. 110 NORTH 

WASHINGTON STREET SUITE NO. 300

ROCKVILLE, MD 20850

FAIRFIELD GATEWAY, LP 618 7/16/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$23,394.19 A $0.00 A

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ. 2029 CENTURY PARK 

EAST, SUITE 800

LOS ANGELES, CA 90067

FAIRFIELD GATEWAY, LP 617 4/6/2018 TRU 2005 RE I, LLC

18-31431

No amounts due per debtor's books and 

records.

$25,151.14

$21,423.24

A

U

$0.00

$0.00

A

U

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ. 2029 CENTURY PARK 

EAST, SUITE 800

LOS ANGELES, CA 90067

FAMILY CENTER OREM SHOPPING 

CENTER, LLC

292 7/20/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$4,837.50

$260,001.81

P

U

$0.00

$260,001.81

P

U

C/O CCA ACQUISITION COMPANY, LLC 

5670 WILSHIRE BLVD SUITE 1250

LOS ANGELES, CA 90036

FAY ESTATES LLC 509 11/12/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$185,645.42

$774,863.54

A

U

$0.00

$774,863.54

A

U

GREENBERG TRAURIG, LLP HEATH B. 

KUSHNICK 200 PARK AVENUE

NEW YORK, NY 10166

FORT GRATIOT CHARTER TOWNSHIP 341 4/30/2018 Toys "R" Us Property 

Company I, LLC

18-31429

No balance due per debtor's books and 

records.

$987.59 U $0.00 U

3720 KEEWAHDIN RD

FORT GRATIOT, MI 48059

FORUM LONE STAR, LP 502 11/11/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$166,146.42

$627,467.66

A

U

$0.00

$627,467.66

A

U

STEVEN R SCHLESINGER 300 GARDEN 

CITY PLAZA, FLOOR 5

GARDEN CITY, NY 11530

Page 3 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

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 Document Page 28 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

FOURTH QUARTER PROPERTIES, VII, INC. 544 11/12/2018 TRU 2005 RE I, LLC

18-31431

Post-petition rent paid by debtor through 

rejection date of 10/17/18; November 

fees not due.

$77,766.41

$5,500.00

A

U

$0.00

$0.00

A

U

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ 2029 CENTURY PARK EAST, 

SUITE 800

LOS ANGELES, CA 90067-2909

G&I VIII LAKESHORE MARKETPLACE, LLC 540 11/12/2018 TRU 2005 RE I, LLC

18-31431

Rejection damages estimated at $173,750 

and no post-petition amounts due per 

debtor's books and records.

$46,598.58

$238,088.92

A

U

$0.00

$173,750.48

A

U

HARTMAN SIMONS & WOOD C/O IRENE B. 

VANDER ELS, ESQ. 6400 POWERS FERRY 

RD. NW #400

ATLANTA, GA 30339

GATEWAY CENTER PROPERTIES III LLC 480 11/9/2018 TRU 2005 RE I, LLC

18-31431

Estimated rejection damages per debtor's 

records for one year of rent, CAM, and 

taxes is $1,461,635.

$2,462,836.82 U $1,461,635.29 U

60 COLUMBUS CIRCLE, 19TH FLOOR

NEW YORK, NY 10023

GREAT EAST MALL, INC. 675 3/28/2018 TRU 2005 RE I, LLC

18-31431

No amount due per debtor's books and 

records.

$8,386.21 U $0.00 U

ATTN: LEGAL DEPARTMENT 5577 

YOUNGSTOWN-WARREN ROAD

NILES, OH 44446

HAMILTON CROSSING CMBS, LLC, BY 

CBL & ASSOCIATES MANAGEMENT INC., 

AS MANAGING AGENT

654 TRU 2005 RE I, LLC

18-31431

No rejection damages due for property 

owned by debtor; no post-petition 

amounts due per debtor's books and 

records.

$812.24

$20,589.41

A

U

$0.00

$0.00

A

U

CALEB T. HOLZAEPFEL 736 GEORGIA 

AVENUE, SUITE 300

CHATTANOOGA, TN 37402

HAP PROPERTY OWNER, L.P. 550 11/12/2018 TRU 2005 RE I, LLC

18-31431

October 2018 rent paid by debtor, check 

#7732981.

$9,123.73

$199,650.00

A

U

$0.00

$199,650.00

A

U

SAMANTHA L. TZOBERI, ESQ. 5555 

GLENRIDGE CONNECTOR, SUITE 800

ATLANTA, GA 30342

HARBISON COMMUNITY ASSOCIATION 483 6/14/2018 TRU 2005 RE I, LLC

18-31431

Amount due per debtor's books and 

records is $1,376.65.

$5,588.74 A $1,376.65 A

106 HILLPINE ROAD

COLUMBIA, SC 29212

Page 4 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 29 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

HAREFF LLC 424 10/31/2018 TRU 2005 RE I, LLC

18-31431

Estimated rejection damages per debtor's 

records for one year of rent, CAM, and 

taxes is $154,950; one-year rejection 

damages per creditor total $230,474, and 

also included in the claim are $151,224 in 

estimated repair, maintenance, and other 

fees.

$381,698.39 U $154,950.39 U

MICHAEL BEST & FRIEDRICH LLP 

JONATHAN GOLD 601 PENNSYLVANIA 

AVENUE NW SUITE 700 SOUTH

WASHINGTON, DC 20004

IN RETAIL FUND WOODFIELD COMMONS, 

LLC

596 11/21/2018 TRU 2005 RE I, LLC

18-31431

Estimated rejection damages per debtor's 

records for rent, CAM, and taxes for 15% 

of remaining term is $1,034,544.

$1,594,943.98 U $1,034,543.80 U

CONNOLLY GALLAGHER LLP KAREN C. 

BIFFERATO, ESQ. 1000 NORTH WEST 

STREET, 14TH FLOOR

WILMINGTON, DE 19801

IRC UNIVERSITY CROSSINGS, LLC 281 7/16/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$45,253.90 A $0.00 A

1000 NORTH WEST STREET 14TH FLOOR

WILMINGTON, DE 19801

IRC UNIVERSITY CROSSINGS, LLC 391 10/22/2018 TRU 2005 RE I, LLC

18-31431

Creditor filed for rejection damages 

based on one year of rent, CAM, and 

taxes. Per debtor's records, the lease ends 

1/31/19, six months after rejection date; 

estimated rejection damages for prorated 

period are $110,459.

$254,610.61 U $110,459.40 U

1000 NORTH WEST STREET 14TH FLOOR

WILMINGTON, DE 19801

JDK TOWNLINE LLC 411 10/26/2018 Toys "R" Us Property 

Company I, LLC

18-31429

No amounts due per debtor's books and 

records.

$1,627.22 U $0.00 U

C/O SCHENK ANNES TEPPER CAMPBELL 

LTD. ATTN: ROBERT D. TEPPER, TOMASZ 

A. SOBIERAJ 311 S. WACKER DRIVE SUITE 

2500

CHICAGO, IL 60606

JEFFERSON MALL CMBS, LLC, BY CBL & 

ASSOCIATES MANAGEMENT INC., AS 

MANAGING AGENT

655 TRU 2005 RE I, LLC

18-31431

No rejection damages due for property 

owned by debtor; no post-petition 

amounts due per debtor's books and 

records.

$10,120.01

$29,900.59

A

U

$0.00

$234.52

A

U

CALEB T. HOLZAEPFEL 736 GEORGIA 

AVENUE, SUITE 300

CHATTANOOGA, TN 37402

Page 5 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 30 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

JLP-CRANBERRY LLC 671 4/6/2018 TRU 2005 RE I, LLC

18-31431

No amount due per debtor's books and 

records.

$247.64 U $0.00 U

TOD H. FRIEDMAN 4300 E. FIFTH AVE.

COLUMBUS, OH 43219

KIR MINNETONKA L.P. 638 1/22/2019 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$153,357.86

$1,176,407.10

A

U

$0.00

$1,176,407.10

A

MORGAN LEWIS & BOCKIUS LLP NEIL E. U

HERMAN, ESQ. 101 PARK AVENUE

NEW YORK, NY 10178

LEA COMPANY LLC AS SUCCESSOR IN 

INTEREST TO LEA COMPANY, A VA 

GENERAL PARTNERSHIP

528 11/12/2018 TRU 2005 RE I, LLC

18-31431

Rejection damages estimated at $400,601 

plus pre-petition amount due of $3,812 

per debtor's books and records.

$427,796.83 U $404,412.88 U

C/O PALMS ASSOCIATES PO BOX 2008

VIRGINIA BEACH, VA 23450

LONG CREEK WATERSHED 

MANAGEMENT DISTRICT 

696 7/2/2018 TRU 2005 RE I, LLC

18-31431

No amount due per debtor's books and 

records.

$6,724.01 A $0.00 A

ATTN: EXECUTIVE DIRECTOR C/O 

CCSWCD 35 MAIN STREET, SUITE #3

WINDHAM, ME 04062

MALLVIEW PLAZA COMPANY, LTD. 290 7/20/2018 MAP Real Estate, LLC

18-31430

Rejection damages calculated at 

$236,603 per debtor's books and records.

$256,602.92 U $236,603.11 U

ATTN: JONATHAN KHOURI 27500 

DETROIT ROAD SUITE 300

WESTLAKE, OH 44145

MASCOT LLC AND JEFAN LLC 582 11/16/2018 TRU 2005 RE I, LLC

18-31431

Estimated rejection damages per debtor's 

records for one year of rent, CAM, and 

taxes is $357,579; one-year rejection 

damages per creditor total $449,311, and 

also included in the claim are $339,021 in 

estimated repair, maintenance, and other 

fees.

$788,332.37 U $357,579.14 U

C/O KIN PROPERTIES, INC. 185 NW 

SPANISH RIVER BLVD. SUITE 100

BOCA RATON, FL 33431

Page 6 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 31 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

MATTONE GROUP RACEWAY LLC, JMM 

RACEWAY LLC, AND GART ROOSEVELT 

ASSOCIATES LLC, AS TENANTS IN 

COMMON

594 11/21/2018 TRU 2005 RE I, LLC

18-31431

Rejection damages calculated at 

$1,370,973 and no post-petition amounts 

due per debtor's books and records.

$61,720.55

$1,527,486.74

A

U

$0.00

$1,370,973.15

A

U

C/O ARENT FOX LLP ATTN: GEORGE 

ANGELICH AND PHILLIP KHEZRI 1301 

AVENUE OF THE AMERICAS, FLOOR 42

NEW YORK, NY 10019

MIDMALL RESOURCES LIMITED 

PARTNERSHIP

520 11/12/2018 TRU 2005 RE I, LLC

18-31431

Estimated rejection damages per debtor's 

records for one year of rent, CAM, and 

taxes is $396,597; creditor calculates oneyear damages based on average annual 

amount over life of lease with escalators.

$503,197.69 U $396,597.39 U

NATIONAL REALTY & DEVELOPMENT 

CORP. WAYNE E. HELLER, ESQ. 3 

MANHATTANVILLE ROAD, SUITE 202

NATIONAL LAND RESOURCES, LP 525 11/12/2018 TRU 2005 RE I, LLC

18-31431

Rejection damages estimated at $344,698 

per debtor's records; no support for other 

amounts claimed.

$400,422.15 U $344,698.17 U

NATIONAL REALTY & DEVELOPMENT 

CORP. WAYNE E. HELLER, ESQ. 3 

MANHATTANVILLE ROAD, SUITE 202

PURCHASE, NY 10577

NORTHRIDGE OWNER, L.P. 689 4/6/2018 TRU 2005 RE I, LLC

18-31431

No amounts due per debtor's books and 

records.

$4,235.28

$6,735.28

A

U

$0.00

$0.00

A

U

BALLARD SPAHR LLP DUSTIN P. BRANCH 

ESQ. 2029 CENTURY PARK EAST SUITE 800

LOS ANGELES, CA 90067

PACIFIC/DSLA NO. 2, A CALIFORNIA 

GENERAL PARTNERSHIP

624 8/2/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$23,104.23 A $0.00 A

LAW OFFICES OF GLEN DRESSER GLEN 

DRESSER 5250 LANKERSHIM BLVD, SUITE 

500

N HOLLYWOOD, CA 91601

PARK BROOKE HAZLET LLC 712 3/6/2019 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$34,204.64 A $0.00 A

C/O PRIDE PROPERTY MANAGEMENT 

CORP. ATTN: ALEX K. KUFFEL 11 NEW 

STREET

ENGLEWOOD CLIFFS, NJ 07632

Page 7 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 32 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

POTOMAC RUN, LLC 487 11/8/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$32,073.76

$497,417.00

A

U

$0.00

$497,417.00

A

MORGAN LEWIS & BOCKIUS LLP NEIL E. U

HERMAN, ESQ. 101 PARK AVENUE

NEW YORK, NY 10178

PRTC, LP., A CALIFORNIA LIMITED 

PARTNERSHIP

479 11/8/2018 Toys "R" Us Property 

Company I, LLC

18-31429

No post-petition amounts due per debtor's 

books and records.

$15,117.06 A $0.00 A

ALLAN D. SARVER ESQ. 16000 VENTURA 

BLVD., SUITE 1000

ENCINO, CA 91436

RAMCO-GERSHENSON, INC. 681 4/5/2018 TRU 2005 RE I, LLC

18-31431

No amount due per debtor's books and 

records.

$26,085.65 U $0.00 U

STARK & STARK, PC C/O THOMAS S. 

ONDER, ESQ. 993 LENOX DRIVE

LAWRENCEVILLE, NJ 08648

RCG-LITHONIA MARKETPLACE, LLC 557 11/12/2018 TRU 2005 RE I, LLC

18-31431

Rejection claim calculated at $333,226 

and no post-petition amounts due per 

debtor's books and records.

$108,931.98

$364,354.05

A

U

$0.00

$333,225.79

A

U

C/O HARTMAN SIMONS & WOOD ATTN: 

IRENE B. VANDER ELS, ESQ. 6400 POWERS 

FERRY RD. NW #400

ATLANTA, GA 30339

RPAI NEWNAN CROSSING II, LLC 495 11/11/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$12,301.72

$213,750.74

A

U

$0.00

$213,750.74

A

U

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ. 2029 CENTURY PARK 

EAST, SUITE 800

LOS ANGELES , CA 90067-2909

RUNNING HILL SP LLC 585 11/16/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$24,224.01

$287,196.03

A

U

$0.00

$287,196.03

A

U

C/O MIRICK O'CONNELL ATTN: PAUL W. 

CAREY, ESQ & KATE P. FOLEY, ESQ 100 

FRONT STREET

WORCESTER, MA 01608

RVT ERIE MARKETPLACE LLC 274 7/9/2018 MAP Real Estate, LLC

18-31430

Rejection damages calculated at 

$128,364 and pre-petition amount due of 

$12,395 per debtor's books and records.

$209,938.24 U $140,758.38 U

3300 ENTERPRISE PARKWAY

BEACHWOOD, OH 44122

Page 8 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 33 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

SANTA ROSA SOUTHSIDE LLC, C/O 

RETAIL OPPORTUNITY INVESTMENTS 

CORP.

546 11/12/2018 TRU 2005 RE I, LLC

18-31431

No amounts due per debtor's books and 

records.

$14,968.10

$3,728.01

A

U

$0.00

$0.00

A

U

BAYARD, P.A. C/O EVAN T. MILLER 600 

NORTH KING STREET, SUITE 400

WILMINGTON, DE 19801

SCI ITC SOUTH FUND 102 5/7/2018 TRU 2005 RE I, LLC

18-31431

No amounts due per debtor's books and 

records.

$35,743.44 U $0.00 U

SIRLIN LESSER & BENSON, P.C. DANA S. 

PLON, ESQUIRE 123 SOUTH BROAD 

STREET, SUITE 2100

PHILADELPHIA, PA 19109

SCI ITC SOUTH FUND 284 7/16/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$139,503.56 A $0.00 A

SIRLIN LESSER & BENSON, P.C. DANA S. 

PLON, ESQUIRE 123 SOUTH BROAD 

STREET, SUITE 2100

PHILADELPHIA, PA 19109

SCI ITC SOUTH FUND 351 9/14/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$12,935.57

$281,987.63

A

U

$0.00

$281,987.63

A

U

SIRLIN LESSER & BENSON, P.C. DANA S. 

PLON, ESQUIRE 123 SOUTH BROAD 

STREET, SUITE 2100

PHILADELPHIA, PA 19109

SDC INVESTMENTS, INC. 628 7/11/2018 TRU 2005 RE I, LLC

18-31431

CAM amounts asserted per claim paid by 

debtor, check numbers 7732221 and 

8664245.

$16,868.98 A $0.00 A

THE VILLAGE SHOPPING CENTER C/O 

RSC ASSOCIATES, INC. 3120 COHASSET 

ROAD, SUITE 5

CHICO, CA 95973

SMITHTOWN VENTURE LIMITED 

LIABILITY COMPANY

501 11/8/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$213,817.56

$1,525,587.00

A

U

$0.00

$1,525,587.00

A

MORGAN LEWIS & BOCKIUS LLP NEIL E U

HERMAN, ESQ 101 PARK AVENUE

NEW YORK, NY 10178

Page 9 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 34 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

SPARKY BABY LLC 491 11/9/2018 MAP Real Estate, LLC

18-31430

Rejection damages estimated at $523,908 

and no post-petition balance due per 

debtor's books and records.

$101,717.69

$1,237,393.05

A

U

$0.00

$523,907.83

A

U

KJK MEILISSA A. YASINOW 1375 E. 9TH 

ST., 29TH FL.

CLEVELAND, OH 44114

SPOKANE VALLEY PLAZA 383 7/13/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$12,595.32 A $0.00 A

T/A CLIFFORD ENTITIES LLC

SPOKANE, WA 99201

SPRINGSAN COMPANY LLC 426 10/31/2018 MAP Real Estate, LLC

18-31430

Estimated rejection damages per debtor's 

records for one year of rent, CAM, and 

taxes is $306,818; one-year rejection 

damages per creditor total $383,296, and 

also included in the claim are $147,296 in 

estimated repair, maintenance, and other 

fees.

$530,591.67 U $306,818.18 U

MICHAEL BEST & FRIEDRICH LLP 

JONATHAN GOLD 601 PENNSYLVANIA 

AVENUE NW SUITE 700 SOUTH

WASHINGTON, DC 20004

SUNSET HILLS OWNER LLC 598 11/21/2018 TRU 2005 RE I, LLC

18-31431

Rejection damages calculated at 

$893,267 and no post-petition amounts 

due per debtor's books and records.

$65,600.21

$1,053,487.09

A

U

$0.00

$893,266.98

A

U

BY SANSONE GROUP, LLC, ITS MANAGER 

MARSHALL C TURNER 190 CARONDELET 

PLAZA, SUITE 600

ST LOUIS, MO 63105

TECH ONE ASSOCIATES, L.P. 481 11/9/2018 MAP Real Estate, LLC

18-31430

No post-petition amounts due per debtor's 

books and records.

$93,585.66 A $0.00 A

KNOX MCLAUGHLIN GORNALL & 

SENNETT, P.C. GUY C. FUSTINE, ESQUIRE 

120 WEST TENTH STREET

ERIE, PA 16501

TERENCE M. TOMBARI, AS CO-TRUSTEE 

OF THE WILLIAM A. TOMBARI SR. 

MARITAL TRUST

496 11/9/2018 TRU 2005 RE I, LLC

18-31431

Estimated rejection damages per debtor's 

records for one year of rent, CAM, and 

taxes is $170,715.

$384,239.10 U $170,714.58 U

LUKINS & ANNIS, P.S. C/O TREVOR R. 

PINCOCK 717 W. SPRAGUE AVE., SUITE 

1600

SPOKANE, WA 99201

Page 10 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 35 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

THF CHESTERFIELD DEVELOPMENT, LLC 555 11/12/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$92,774.59

$252,804.24

A

U

$0.00

$252,804.24

A

MCELROY, DEUTSCH, MULVANEY & U

CARPENTER, LLP C/O DAVID P. PRIMACK, 

ESQ. 300 DELAWARE AVE., SUITE 770

WILMINGTON, DE 19801

UE MUNDY STREET LP 530 11/12/2018 MAP Real Estate, LLC

18-31430

Rejection damages estimated at $176,735 

per debtor's records; additional support 

needed for school taxes listed on proof of 

claim.

$466,152.99 U $195,344.20 U

C/O URBAN EDGE PROPERTIES 210 ROUTE 

4 EAST ATTN: MEI CHENG

PARAMUS, NJ 07652

VALLEY VIEW (UNIT 1) L.L.C. 537 11/12/2018 TRU 2005 RE I, LLC

18-31431

Rejection damages estimated at $193,166 

and no post-petition balance due per 

debtor's books and records.

$102,158.02

$273,570.22

A

U

$0.00

$193,165.75

A

U

C/O FRIEDMAN REAL ESTATE 

MANAGEMENT ATTN: MEGAN ODELL, 

ESQ. 34975 WEST TWELVE MILE ROAD

FARMINGTON HILLS, MI 48331

WATERFORD UTILITY COMMISSION 561 11/13/2018 TRU 2005 RE I, LLC

18-31431

Utilities being paid by debtor as they 

become due.

$1,575.57 P $0.00 P

C/O AVENA & KEPPLE, LLC ATTN: 

NICHOLAS KEPPLE P.O. BOX 1445

PAWCATUCK, CT 06379

WEINGARTEN NOSTAT, INC. 445 11/2/2018 TRU 2005 RE I, LLC

18-31431

Rejection damages calculated at 

$366,786 per debtor's books and records.

$386,861.78 U $366,786.29 U

WEINGARTEN REALTY INVESTORS ATTN: 

LITIGATION DIVISION 2600 CITADEL 

PLAZA DR., SUITE 125

HOUSTON, TX 77008

WESTLAKE SHOPPING CENTER, LLC 633 7/11/2018 TRU 2005 RE I, LLC

18-31431

No post-petition amounts due per debtor's 

books and records.

$56,917.00 A $0.00 A

ATTN: ADAM D. STEIN-SAPIR GREELEY 

SQUARE STATION P.O. BOX 20188

NEW YORK, NY 10001

WESTLAKE SHOPPING CENTER, LLC 270 7/11/2018 TRU 2005 RE I, LLC

18-31431

Lease rejected 10/4/2018 and lease 

expires 1/31/2019, which is roughly 7 

years and 4 months; creditor claims the 

period is 8 years, 4 months. The 

corrected rejection calculation based on 

the $600K annual amount is $660,000.

$900,000.00 U $660,000.00 U

ATTN: ADAM D. STEIN-SAPIR GREELEY 

SQUARE STATION P.O. BOX 20188

NEW YORK, NY 10001

Page 11 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 36 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Reduced/Reconciled Per Debtor's Books and Records

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 1

Second Omnibus Objection

WILLIAMS PARKWAY, LLC 531 11/12/2018 Toys "R" Us Property 

Company I, LLC

18-31429

No post-petition amounts due per debtor's 

books and records.

$24,184.05 A $0.00 A

GREENBAUM ROWE SMITH & DAVIS LLP 

ATTN: NANCY ISAACSON, ESQ. 75 

LIVINGSTON AVENUE

ROSELAND, NJ 07068

WILLIAMS PARKWAY, LLC 538 11/12/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Rejection damages estimated at $790,653 

per debtor's records; remaining claim 

reduced for cleaning, attorney's fees, and 

prepaid commission.

$1,581,720.50 U $796,059.21 U

GREENBAUM ROWE SMITH & DAVIS LLP 

ATTN: NANCY ISAACSON, ESQ. 75 

LIVINGSTON AVENUE

ROSELAND, NJ 07068

Totals for 73 Claims $28,784,886.47 $19,699,581.50

Page 12 of 12 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 37 of 66
Schedule 2 

Insufficient Documentation Claims 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 38 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Insufficient Support Attached to Claim

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 2

Second Omnibus Objection

ALEXANDER, BONNIE 447 11/6/2018 TRU 2005 RE I, LLC

18-31431

Proof of claim includes medical bills and 

a site inspection report, but additional 

support is needed to support amount 

claimed.

$500,000.00 U $0.00 U

C/O THE REARDON LAW FIRM PC ATTN: 

KELLY E REARDON ESQ 160 HEMPSTEAD 

STREET PO DRAWER 1430

NEW LONDON, CT 06320

BATTLE, RAYMOND E 417 10/29/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Proof of claim only includes medical bills 

totaling $3,201; claimant does not state 

how or where injury occurred or provide 

support for amount claimed.

$80,000.00 U $0.00 U

C/O LAW OFFICE OF ANDREW S KRYDER 

LLC ATTN: ANDREW S KRYDER 134 N 

LASALLE ST 1515

CHICAGO, IL 60602

BONACASSIO, MAGGIE 408 10/26/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Need additional documentation to 

support amount claimed.

$16,000.00 U $0.00 U

C/O LAW OFFICES OF BRIAN J 

MONGELUZZO ATTN: BRIAN J 

MONGELLUZZO 1336 WEST MAIN STREET 

SUIT 1B

WATERBURY, CT 06708

BRE SKYVIEW RETAIL OWNER LLC 524 11/12/2018 TRU 2005 RE I, LLC

18-31431

Additional support required to determine 

store.

$4,322.42

$4.92

A

U

$0.00

$0.00

A

U

SHOPCORE PROPERTIES LINDA 

MADWAY, ESQ. TWO LIBERTY PLACE 50 

S. 16TH STREET, SUITE 3325

PHILADELPHIA , PA 19102 

COVINGTON, WYZETTA 331 8/31/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Proof of claim includes itemized listing 

of damages with no supporting 

documents; no basis for claiming $5,900 

priority portion of claim.

$5,900.00

$470,510.00

P

U

$0.00

$0.00

P

U

153 TURNER ASHBY CT

MARTINSVILLE, VA 24112

CRAIG, LINDA 484 11/9/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Need additional support to determine 

where and how injury occurred.

$20,000.00 U $0.00 U

4923 CARIBBEAN WAY W.

BENTON, AR 72019

CROOK, YVONNE 580 11/19/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Need additional documentation to 

support amount claimed.

$19,130.00 U $0.00 U

C/O MIFFLIN & ASSOCIATES ATTN: KEN 

MIFFLIN 4309 SOUTH WESTERN AVENUE

LOS ANGELES, CA 90062

Page 1 of 3 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 39 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Insufficient Support Attached to Claim

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 2

Second Omnibus Objection

HAYAT, AMIRR 457 11/5/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Need additional documentation to 

support amount claimed.

$14,716.39 U $0.00 U

NICOLE BOYD 3467 W. 97TH AVE # 26

WESTMINSTER, CO 80031

ISAS, SERGIO 477 11/8/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Proof of claim provides medical bills 

totaling $8,080; claimant provides no 

support for addittional amounts claimed 

and does not describe how or where 

injury occurred.

$35,000.00 U $0.00 U

C/O THE SOILEAU LAW FIRM, P.C. ATTN: 

CHRISTOPHER R. SOILEAU P.O. BOX 1749

DEER PARK, TX 77536

MARLOW, PATRICIA H. 475 11/8/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Need additional documentation to 

support amount claimed.

$1,000,000.00 U $0.00 U

C/O THE LOVELY LAW FIRM ATTN: 

JARROD MCPHERSON 804 N OAK STREET

MYRTLE BEACH, SC 29577

MATTESON REALTY LLC 680 4/4/2018 TRU 2005 RE I, LLC

18-31431

Need additional support - cannot 

determine store.

$9,446.46 U $0.00 U

C/O NAMDAR REALTY GROUP LLC 150 

GREAT NECK REALTY ROAD, SUITE 304

GREAT NECK, NY 11021

PHILLIPS, DANIELLE 434 10/29/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Need additional documentation to 

support amount claimed.

$300,000.00 U $0.00 U

C/O MORGAN AND MORGAN ATTN: 

DILLON BROZYNA ONE TAMPA CITY 

CENTER SUITE 700

TAMPA, FL 33602

RAF JOPLIN LLC 668 4/6/2018 TRU 2005 RE I, LLC

18-31431

Need additional support - cannot 

determine store.

$98,540.31 U $0.00 U

C/O DAVID A. ELI, ESQ. 3333 RICHMOND 

ROAD, SUITE 320

BEACHWOOD, OH 44122

SHENTEAL-SCHALK, JEAHARA K 459 11/7/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Creditor only includes summary schedule 

itemizing amounts due with no support 

for the amounts claimed or details of 

how, where, or when the injury occurred.

$5,803,194.08 U $0.00 U

4229 SE 63RD AVE

PORTLAND, OR 97206

Page 2 of 3 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 40 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Insufficient Support Attached to Claim

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 2

Second Omnibus Objection

SINCLAIR, ROBERT L 409 10/26/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Need additional documentation to 

support amount claimed.

$75,000.00 U $0.00 U

C/O SCHENDEROVICH SHENDEROVICH 

AND FISHMAN ATTN: MARK T DEL DUCA 

1600 LAW AND FINANCE BLDG 429 4TH 

AVENUE

PITTSBURGH, PA 15219

SLOMEANA, SARAH N 486 11/8/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Proof of claim includes letter from 

attorney listing various medical 

summaries; no bills are included, and 

claimant does not list at which store the 

accident occurred.

$100,000.00 U $0.00 U

C/O WESTMORELAND VESPER 

QUATTRONE AND BEERS ATTN: DARA A 

QUATTRONE, ESQUIRE BAYPORT ONE 

8025 BLACK HORSE PIKE SUITE 500

WEST ATLANTIC CITY, NJ 08232

SULLIVAN, PATRICIA AND TIMOTHY 478 11/8/2018 TRU 2005 RE I, LLC

18-31431

Creditor includes copy of personal injury 

complaint filed against TRU 2005 RE I, 

LLC, but does not include any other 

support or assert a claim amount.

$0.00 U $0.00 U

C/O BRADY & KUNZ ATTN: THOMAS E. 

KUNZ, ESQ. PO BOX 4990 680 HOPPER 

AVENUE, BLDG. C, 2ND FL.

TOMS RIVER, NJ 08754

Totals for 17 Claims $8,551,764.58 $0.00

Page 3 of 3 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 41 of 66
Schedule 3 

Satisfied Lease Claims 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 42 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Assumed Lease - Claim Satisfied

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 3

Second Omnibus Objection

12535 S.E. 82ND AVENUE 365 7/16/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$1.00 A $0.00 A

C/O HUNTINGTON HOLDINGS, INC. JACK 

CORWIN 9595 WILSHIRE BLVD., SUITE 411

BEVERLY HILLS, CA 90212

12535 S.E. 82ND AVENUE LLC 353 9/18/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$629,400.00 U $0.00 U

C/O HUNTINGTON HOLDINGS, INC. JACK 

CORWIN 9595 WILSHIRE BLVD., SWUITE 

411

BEVERLY HILLS, CA 90212

3503 RP CHARLESTON NORTH RIVERS, 

L.L.C.

611 7/16/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$34,188.66 A $0.00 A

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ. 2029 CENTURY PARK 

EAST, SUITE 800

LOS ANGELES, CA 90067-2909

ACF PROPERTY MANAGEMENT, LLC 670 4/6/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$1,082.54 U $0.00 U

MOYE WHITE LLP TIMOTHY M. 

SWANSON 1400 16TH STREET SUITE 600

DENVER, CO 80202

ACF PROPERTY MANAGEMENT, LLC, ON 

BEHALF OF PIPELINE 13 A LP

367 7/13/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$5,453.19 A $0.00 A

MOYE WHITE LLP TIMOTHY M. 

SWANSON 1400 16TH STREET, 6TH FLOOR

DENVER, CO 80202

ALISUE LLC AND FUNDAMENTALS 

COMPANY, INC.

192 6/14/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$156,263.00

$82,379.18

A

U

$0.00

$0.00

A

U

C/O MICHAEL BEST & FRIEDRICH LLP 

ATTN: JONATHAN GOLD 601 

PENNSYLVANIA AVENUE NW SUITE 700 

SOUTH

WASHINGTON, DC 20004

Page 1 of 5 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 43 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Assumed Lease - Claim Satisfied

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 3

Second Omnibus Objection

B SQUARE SC COMPANY LTD 357 7/16/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$71,287.64 A $0.00 A

SOUTHERN MANAGEMENT AND 

DEVELOPMENT, LP STEVEN LEVIN 2300 

NW CORPORATE BLVD. SUITE 135

BOCA RATON, FL 33431

BERWICK-KRAUSZ 558 11/12/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$77,765.33

$7,500.00

A

U

$0.00

$0.00

A

U

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ. 2029 CENTURY PARK 

EAST, SUITE 800

LOS ANGELES, CA 90067-2909

BERWICK-KRAUSZ (ALMADEN SQUARE) 613 7/16/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$119,454.43 A $0.00 A

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ. 2029 CENTURY PARK 

EAST, SUITE 800

LOS ANGELES, CA 90067-2909

BRIXMOR GRAND TRAVERSE I LLC 

(BRIXMOR PROPERTY GROUP, INC.) T/A 

GRAND TRAVERSE-WALMART, 

TRAVERSE CIT 

684 4/5/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$56,188.83 U $0.00 U

C/O BALLARD SPAHR LLP DAVID L. 

POLLACK, ESQ. 1735 MARKET STREET, 

51ST FLOOR

PHILADELPHIA, PA 19103

CAFARO GOVERNOR'S SQUARE 

PARTNERSHIP 

658 3/28/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$45,114.24 U $0.00 U

ATTN: LEGAL DEPARTMENT 5577 

YOUNGSTOWN-WARREN ROAD

NILES, OH 44446

CFT NV DEVELOPMENTS, LLC 280 7/13/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$675,919.43 U $0.00 U

SEYFARTH SHAW LLP JAMES B. SOWKA 

233 S. WACKER DRIVE SUITE 8000

CHICAGO, IL 60606

Page 2 of 5 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 44 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Assumed Lease - Claim Satisfied

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 3

Second Omnibus Objection

CORE BLOOMINGTON COMMONS LLC 321 6/25/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Lease sold to third party - no amounts 

due.

$92,003.16 A $0.00 A

ATTN: JON SPITZ PO BOX 1243

NORTHBROOK, IL 60065

CROWLEY INDEPENDENT SCHOOL 

DISTRICT

372 2/6/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$42,366.05 A $0.00 A

PERDUE BRANDON FIELDER COLLINS & 

MOTT, LLP EBONEY COBB 500 EAST 

BORDER ST, SUITE 640

ARLINGTON, TX 76010

EEC PARK PLACE CERRITOS, LLC 500 11/9/2018 TRU 2005 RE I, LLC

18-31431

Lease assumed per docket #648 - no 

rejection damages due.

$3,997,575.36 U $0.00 U

J. ANDREW DOUGLAS AND WRIGHT KIM 

DOUGLAS 130 S. JACKSON ST

GLENDALE, CA 91205

ESAN LLC 187 6/14/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$17,186.00

$219,739.75

A

U

$0.00

$0.00

A

U

C/O MICHAEL BEST & FRIEDRICH LLP 

ATTN: JONATHAN GOLD 601 

PENNSYLVANIA AVENUE NW SUITE 700 

SOUTH

WASHINGTON, DC 20004

FUNDAMENTALS CO TRUST, 

FUNDAMENTALS CO INC., ANSAN TRUST, 

& GENERAL DELTA CO INC.

194 6/14/2018 TRU 2005 RE II Trust

18-31432

Lease sold to third party - no amounts 

due.

$156,973.00

$65,449.51

A

U

$0.00

$0.00

A

U

C/O MICHAEL BEST & FRIEDRICH LLP 

ATTN: JONATHAN GOLD 601 

PENNSYLVANIA AVENUE NW SUITE 700 

SOUTH

WASHINGTON, DC 20004

GATEWAY PINOLE VISTA, LLC 621 7/16/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$83,683.56 A $0.00 A

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ. 2029 CENTURY PARK 

EAST, SUITE 800

LOS ANGELES, CA 90067-2909

Page 3 of 5 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 45 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Assumed Lease - Claim Satisfied

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 3

Second Omnibus Objection

GATEWAY PINOLE VISTA, LLC 545 11/12/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$33,592.40

$9,075.60

A

U

$0.00

$0.00

A

U

BALLARD SPAHR LLP DUSTIN P. 

BRANCH, ESQ. 2029 CENTURY PARK 

EAST, SUITE 800

LOS ANGELES, CA 90067-2909

GOODRICH CICERO LLC 374 6/22/2018 TRU 2005 RE I, LLC

18-31431

Unliquidated claim - lease assumed per 

docket #648, no amounts due.

$0.00 A $0.00 A

560 SYLVAN AVE - SUITE 2100

ENGLEWOOD CLIFFS, NJ 07632

GOODRICH CICERO LLC 659 4/2/2018 TRU 2005 RE I, LLC

18-31431

Unliquidated claim; lease assumed per 

docket #648 - no amounts due per debtor.

$0.00 U $0.00 U

560 SYLVAN AVE- SUITE 2100

ENGLEWOOD CLIFFS, NJ 07632

GOODRICH CICERO LLC 499 11/9/2018 TRU 2005 RE I, LLC

18-31431

Lease assumed per docket #648 - no 

amounts due per debtor.

$1,768.64 U $0.00 U

560 SYLVAN AVE - SUITE 2100

ENGLEWOOD CLIFFS, NJ 07632

GOODRICH CICERO LLC 622 6/22/2018 TRU 2005 RE I, LLC

18-31431

Unliquidated claim - lease assumed per 

docket #648, no amounts due.

$0.00 A $0.00 A

560 SYLVAN AVE - SUITE 2100

ENGLEWOOD CLIFFS, NJ 07632

KINGSTOWNE PARCEL O L.P. 534 11/12/2018 TRU 2005 RE I, LLC

18-31431

Lease assumed per docket #1163 - no 

rejection damages due.

$547,985.80 U $0.00 U

OFFIT KURMAN PA C/O STEPHEN 

NICHOLS, ESQ. 4800 MONTGOMERY 

LANE, 9TH FLOOR

BETHESDA, MD 20814

MASCOT LLC, JESUE LLC, AND ALISUE 

LLC

204 6/15/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$493,020.00

$73,898.21

A

U

$0.00

$0.00

A

MICHAEL BEST & FRIEDRICH LLP U

JONATHAN GOLD 601 PENNSYLVANIA 

AVENUE NW SUITE 700 SOUTH

WASHINGTON, DC 20004

Page 4 of 5 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 46 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Assumed Lease - Claim Satisfied

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 3

Second Omnibus Objection

NORTHWEST TARGET LLC 695 7/2/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$14,457.38 A $0.00 A

3101 STATE ROAD

BAKERSFIELD, CA 93308

RABANUS CENTER, L.L.C. 323 8/21/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$107,523.00 U $0.00 U

C/O VOGEL LAW FIRM ATTN: CAREN 

STANLEY PO BOX 1389

FARGO, ND 58107-1389

THE CAFARO NORTHWEST PARTNERSHIP 676 3/28/2018 TRU 2005 RE I, LLC

18-31431

Lease assumed per docket #648 - no 

amounts due.

$11,532.16 U $0.00 U

ATTN: LEGAL DEPARTMENT 5577 

YOUNGSTOWN-WARREN ROAD

NILES, OH 44446

TOYS CENTER, LLC, A CALIFORNIA 

LIMITED LIABILITY COMPANY 

705 12/12/2018 TRU 2005 RE I, LLC

18-31431

Lease sold to third party - no amounts 

due.

$67,506.61 U $0.00 U

HEDSTROM & COOPERSMITH, LLP 855 

LAKEVILLE ST., STE. 200 E

PETALUMA, CA 94952

VIKING PARTNERS OVERLAND POINTE 

MARKETPLACE, LLC

632 7/16/2018 TRU 2005 RE I, LLC

18-31431

Lease assumed per docket #648; no 

amounts due per debtor's books and 

records.

$77,909.56 A $0.00 A

EQUITY MANAGEMENT GROUP, INC 

ATTN: KELLY MULLINS 840 EAST HIGH 

STREET

LEXINGTON, KY 40502

Totals for 30 Claims $8,075,243.22 $0.00

Page 5 of 5 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 47 of 66
Schedule 4 

No Liability Claims 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 48 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

No Liability Claims

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 4

Second Omnibus Objection

GDD PROPERTIES LLC 688 4/6/2018 TRU 2005 RE I, LLC

18-31431

Claim appears to be for no amount - 

landlord states they are not associated 

with case.

$0.00 U $0.00 U

475 SOUTH BROADWAY

SALEM, NH 03079

IN RETAIL FUND WOODFIELD COMMONS, 

LLC

282 7/16/2018 TRU 2005 RE I, LLC

18-31431

$0.00 A $0.00 A No amount asserted on proof of claim.

CONNOLLY GALLAGHER LLP KAREN C. 

BIFFERATO, ESQ. 1000 NORTH WEST 

STREET, 14TH FLOOR

WILMINGTON, DE 19801

IN RETAIL FUND WOODSFIELD 

COMMONS, L.L.C.

396 7/16/2018 TRU 2005 RE I, LLC

18-31431

$0.00 A $0.00 A No amount asserted on proof of claim.

CONNOLLY GALLAGHER LLP KAREN C. 

BIFFERATO, ESQ. 1000 NORTH WEST 

STREET, 14TH FLOOR

WILMINGTON, DE 19801

IVT PRICE PLAZA KATY, LLC 549 11/12/2018 Toys "R" Us Property 

Company I, LLC

18-31429

$0.00 U $0.00 U No amount asserted on proof of claim.

INVENTRUST PROPERTY MANAGEMENT, 

LLC RICHARD N. SPRINGER 3025 

HIGHLAND PARKWAY, SUITE 350

DOWNERS GROVE, IL 60515

OVERLOOK TOWNLINE LLC 420 10/30/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Creditor filed claim for same amount 

under the name JDK Townline LLC.

$1,627.22 U $0.00 U

C/O SCHENK ANNES TEPPER CAMPBELL 

LTD. ATTN: ROBERT D. TEPPER, TOMASZ 

A. SOBIERAJ 311 S. WACKER DRIVE SUITE 

2500

CHICAGO, IL 60606

RAMCO NOVI DEVELOPMENT 

ASSOCIATES LIMITED PARTNERSHIP 

710 4/5/2018 TRU 2005 RE I, LLC

18-31431

$0.00 U $0.00 U No amount asserted on claim.

STARK & STARK, PC C/O THOMAS S. 

ONDER, ESQ. 993 LENOX DRIVE

LAWRENCEVILLE, NJ 08648

Page 1 of 2 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 49 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

No Liability Claims

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 4

Second Omnibus Objection

REEP-RTL MILL CREEK NJ, LLC 663 4/5/2018 MAP Real Estate, LLC

18-31430

Unliquidated claim - appears to be for 

store #6623, which is a Toys "R" Us 

Delaware, Inc. store.

$0.00 U $0.00 U

LEVIN MANAGEMENT CORPORATION 

STARK & STARK, PC C/O THOMAS S. 

ONDER, ESQ. 993 LENOX DRIVE

LAWRENCEVILLE, NJ 08648

SDC INVESTMENTS, INC. 677 3/30/2018 TRU 2005 RE I, LLC

18-31431

Creditor claimed all amounts were paid 

up to date - no amount asserted.

$0.00 U $0.00 U

THE VILLAGE SHOPPING CENTER C/O 

RSC ASSOCIATES, INC. 3120 COHASSET 

ROAD, SUITE 5

CHICO, CA 95973

STAR-WEST LOUIS JOLIET, LLC 314 8/4/2018 TRU 2005 RE I, LLC

18-31431

Landlord listed per debtor is SAMJENN 

Associates, who also filed claim #508 for 

rejection damages.

$1,110,913.80

$2,305,194.64

A

U

$0.00

$0.00

A

U

C/O BALLARD SPAHR LLP ATTN:DUSTIN 

P. BRANCH, ESQ. 2029 CENTURY PARK 

EAST SUITE 800

LOS ANGELES, CA 90067-2909

THE LANDING AT ARBOR PLACE II, LLC, 

BY CBL & ASSOCIATES MANAGEMENT, 

INC, AS MANAGING AGENT

364 10/18/2018 Toys "R" Us Property 

Company I, LLC

18-31429

No rejection damages due for property 

owned by debtor.

$105,366.60 U $0.00 U

CALEB HOLZAEPFEL 736 GEORGIA 

AVENUE, SUITE 300

CHATTANOOGA, TN 37402

TWO STREET PLAZA 532 11/12/2018 Toys "R" Us Property 

Company I, LLC

18-31429

$0.00 U $0.00 U No amount asserted in proof of claim.

C/O ALLAN B. SCHNEIROV 1600 MARKET 

STREET, SUITE 3600

PHILADELPHIA, PA 19103

Totals for 11 Claims $3,523,102.26 $0.00

Page 2 of 2 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 50 of 66
Schedule 5 

Satisfied Tax Claims 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 51 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Tax Claims - Paid by Debtor

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 5

Second Omnibus Objection

ANDERSON COUNTY 567 11/13/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$5,953.02 P $0.00 P

TREASURER PO BOX 1658

ANDERSON, SC 29622-1658

ARIZONA DEPARTMENT OF REVENUE 315 8/9/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$10,025.66 A $0.00 A

OFFICE OF THE ARIZONA ATTORNEY 

GENERAL C/O TAX, BANKRUPTCY AND 

COLLECTION SCT 2005 N CENTRAL AVE, 

SUITE 100

PHOENIX, AZ 85004

ARIZONA DEPARTMENT OF REVENUE 458 11/6/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$87.69

$99.30

P

U

$0.00

$0.00

P

U

OFFICE OF THE ARIZONA ATTORNEY 

GENERAL C/O TAX, BANKRUPTCY AND 

COLLECTION SCT 2005 N CENTRAL AVE, 

SUITE 100

PHOENIX, AZ 85004

ARIZONA DEPARTMENT OF REVENUE 233 6/25/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$142.69

$126.80

P

U

$0.00

$0.00

P

U

OFFICE OF THE ARIZONA ATTORNEY 

GENERAL C/O TAX, BANKRUPTCY AND 

COLLECTION SCT 2005 N CENTRAL AVE, 

SUITE 100

PHOENIX, AZ 85004

BELL COUNTY TAX APPRAISAL DISTRICT 369 1/22/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$32,720.35 A $0.00 A

C/O LEE GORDON P.O. BOX 1269

ROUND ROCK, TX 78680-1269

BRAZOS COUNTY, TEXAS 370 1/22/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$47,976.15 A $0.00 A

MCCREARY, VESELKA, BRAGG & ALLEN, 

P.C. LEE GORDON P.O. BOX 1269

ROUND ROCK, TX 78680-1269

BREVARD COUNTY TAX COLLECTOR 403 10/24/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$55,415.25 S $0.00 S

HONORABLE LISA CULLEN, CFC P.O. BOX 

2500

TITUSVILLE, FL 32781

Page 1 of 9 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 52 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Tax Claims - Paid by Debtor

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 5

Second Omnibus Objection

CITY OF BANGOR 507 11/12/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$46,569.93 S $0.00 S

73 HARLOW ST

BANGOR, ME 04401

CITY OF BOWLING GREEN 342 4/30/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$5,214.86 P $0.00 P

1017 COLLEGE STREET PO BOX 1410

BOWLING GREEN, KY 42102

CITY OF JACKSON TENNESSEE 407 10/25/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$537.00 S $0.00 S

PROPERTY TAX 101 E MAIN ST STE 101

JACKSON, TN 38301

CITY OF KATY 6 4/6/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$18,534.37

$0.00

S

P

$0.00

$0.00

S

MICHAEL J. DARLOW 1235 NORTH LOOP P

WEST SUITE 600

HOUSTON, TX 77008

CITY OF WACO AND/OR WACO 

INDEPENDENT SCHOOL DISTRICT

371 2/6/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$62,209.24 A $0.00 A

MCCREARY, VESELKA, BRAGG & ALLAN, 

P.C. LEE GORDON PO BOX 1269

ROUND ROCK, TX 78680-126

CLACKAMAS COUNTY ASSESSMENT & 

TAX

464 11/8/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$81,150.75

$87,150.75

S

P

$0.00

$0.00

S

P

150 BEAVERCREEK RD

OREGON CITY, OR 97045

COUNTY OF BUTTE CALIFORNIA 490 11/8/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$48,108.30 S $0.00 S

TAX COLLECTOR 25 COUNTY CENTER 

DRIVE

OROVILLE, CA 95965-3367

DOUGLAS COUNTY, NEBRASKA 112 5/11/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$1,550.10 P $0.00 P

DOUGLAS COUNTY ATTORNEY'S OFFICE 

909 CIVIC CENTER, 1819 FARNAM ST.

OMAHA, NE 68183

Page 2 of 9 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 53 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Tax Claims - Paid by Debtor

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 5

Second Omnibus Objection

EL PASO COUNTY TREASURER 440 10/31/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$93,807.87

$93,807.87

S

P

$0.00

$0.00

S

P

PO BOX 2018

COLORADO SPRINGS, CO 80901

FRANCHISE TAX BOARD 327 8/20/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$800.00 P $0.00 P

BANKRUPTCY SECTION MS A340 PO BOX 

2952

SACRAMENTO, CA 95812-2952

GREGG COUNTY 257 6/28/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$33,381.93 S $0.00 S

C/O LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP ATTN: ELIZABETH 

WELLER 2777 N. STEMMONS FREEWAY 

SUITE 1000

DALLAS, TX 75207

GREGG COUNTY 652 1/31/2019 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$33,381.93 A $0.00 A

LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP 2777 N. STEMMONS 

FREEWAY SUITE 1000

DALLAS, TX 75207

GREGG COUNTY 644 1/22/2019 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$33,381.93

$33,381.93

S

A

$0.00

$0.00

S

A

LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP ATTN: ELIZABETH 

WELLER, LAURIE A SPINDLER 2777 N. 

STEMMONS FRWY STE 1000

DALLAS, TX 75207

HARRIS COUNTY 376 2/1/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$483,117.62 A $0.00 A

LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP JOHN P. DILLMAN PO BOX 

3064

HOUSTON, TX 77253-3064

HARRIS COUNTY, ET AL 119 5/15/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$304,166.36 S $0.00 S

LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP JOHN P. DILLMAN PO BOX 

3064

HOUSTON, TX 77253-3064

Page 3 of 9 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 54 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Tax Claims - Paid by Debtor

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 5

Second Omnibus Objection

HARRIS COUNTY, ET AL 377 9/22/2017 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$495,504.84 A $0.00 A

LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP JOHN P. DILLMAN PO BOX 

3064

HOUSTON, TX 77253-3064

HOUSTON COUNTY GEORGIA 650 6/12/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$15,203.71 A $0.00 A

TAX COMMISSIONER PO DRAWER 69

PERRY, GA 31069-0069

HOUSTON COUNTY REVENUE 

COMMISSIONER

343 5/4/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$1,489.71 P $0.00 P

PO DRAWER 6406

DOTHAN, AL 36304

HUMBLE INDEPENDENT SCHOOL 

DISTRICT

5 4/6/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$51,245.92 S $0.00 S

CARL O. SANDIN 1235 NORTH LOOP WEST 

SUITE 600

HOUSTON, TX 77008

JACKSON COUNTY OREGON 415 10/26/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$65,322.22

$2,211.22

S

P

$0.00

$0.00

S

P

TAXATION OFFICE PO BOX 1569

MEDFORD, OR 97501

KATY MANAGEMENT DISTRICT # 1 

(HFBM4)

1 4/6/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$30,464.13 S $0.00 S

CARL O. SANDIN 1235 NORTH LOOP WEST 

SUITE 600

HOUSTON, TX 77008

LOS ANGELES COUNTY TREASURER AND 

TAX COLLECTOR

640 1/17/2019 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$177,355.53 S $0.00 S

PO BOX 54110

LOS ANGELES, CA 90054-0110

Page 4 of 9 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 55 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Tax Claims - Paid by Debtor

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 5

Second Omnibus Objection

LUBBOCK CENTRAL APPRAISAL 

DISTRICT

393 10/22/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$59,491.15 S $0.00 S

LAURA J. MONROE P.O. BOX 817

LUBBOCK, TX 79408

MARION COUNTY COLLECTOR 414 9/17/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$50,593.21 S $0.00 S

P.O. BOX 970

OCALA, FL 34478-0970

MCLENNAN COUNTY 121 5/16/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$17,767.82 S $0.00 S

ATTN: DIANE W. SANDERS P.O. BOX 17428

AUSTIN, TX 78760

MCLENNAN COUNTY 642 1/24/2019 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$17,034.37

$17,034.37

S

A

$0.00

$0.00

S

A

DIANE W. SANDERS P.O. BOX 17428

AUSTIN, TX 78760

MIAMI-DADE COUNTY TAX COLLECTOR 359 4/2/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$205,031.39 A $0.00 A

FINANCE DEPT, TAX COLLECTION 

DIVISION 200 NW 2ND AVENUE, SUITE 

#430

MIAMI, FL 33128

MIDLAND COUNTY 392 10/22/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$1,892.59 S $0.00 S

LAURA J. MONROE PO BOX 817

LUBBOCK, TX 79408

MONTEREY COUNTY TAX COLLECTOR 513 11/12/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$79,676.42 S $0.00 S

PO BOX 891

SALINAS, CA 93902

MONTGOMERY COUNTY 442 11/1/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$81,859.63 S $0.00 S

C/O LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP PO BOX 3064

HOUSTON, TX 77253-3064

Page 5 of 9 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 56 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Tax Claims - Paid by Debtor

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 5

Second Omnibus Objection

PIERCE COUNTY FINANCE DEPARTMENT 17 4/2/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$78,438.24 S $0.00 S

950 FAWCETT AVE, STE 100

TACOMA, WA 98402

RAMSEY COUNTY PROPERTY TAX 

RECORDS & ELECTION SERVICES

452 11/2/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$129,282.00 S $0.00 S

ATTN TREASURER'S OFFICE 90 WEST 

PLATO BLVD

SAINT PAUL, MN 55107

SEDGWICK COUNTY 340 5/7/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$41,025.12 S $0.00 S

OFFICE OF THE COUNTY COUNSELOR 

ATTN: PATRICIA J. PARKER 525 N MAIN 

SUITE 359

WICHITA, KS 67203-3790

SMITH COUNTY 653 1/31/2019 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$21,216.47 A $0.00 A

LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP 2777 N. STEMMONS 

FREEWAY SUITE 1000

DALLAS, TX 75207

SMITH COUNTY 285 6/28/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$23,811.54 S $0.00 S

C/O LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP ATTN: ELIZABETH 

WELLER 2777 N. STEMMONS FREEWAY 

SUITE 1000

DALLAS, TX 75207

SMITH COUNTY 645 1/22/2019 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$21,216.47

$21,216.47

S

A

$0.00

$0.00

S

A

LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP ATTN: ELIZABETH 

WELLER, LAURIE A SPINDLER 2777 N. 

STEMMONS FRWY STE 1000

DALLAS, TX 75207

SNOHOMISH COUNTY TREASURER 386 4/2/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$74,412.40 S $0.00 S

3000 ROCKEFELLER AVE M/S 501

EVERETT, WA 98201

Page 6 of 9 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 57 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Tax Claims - Paid by Debtor

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 5

Second Omnibus Objection

SNOHOMISH COUNTY TREASURER 394 10/23/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$41,057.12

$41,057.12

S

P

$0.00

$0.00

S

P

3000 ROCKEFELLER AVE M/S 501

EVERETT, WA 98201

SNOHOMISH COUNTY TREASURER 381 8/6/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$37,458.58 A $0.00 A

3000 ROCKEFELLER AVE M/S 501

EVERETT, WA 98201

SONOMA COUNTY TAX COLLECTOR 568 11/13/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$31,163.28 S $0.00 S

585 FISCAL DR., STE 100

SANTA ROSA, CA 95403

TARRANT COUNTY 387 7/9/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$33,046.19 A $0.00 A

ELIZABETH WELLER LAURIE A SPINDLER 

LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP 2777 N. STEMMONS FRWY, 

STE 1000

DALLAS, TX 75207

TARRANT COUNTY 384 1/29/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$36,350.81 A $0.00 A

ELIZABETH WELLER LAURIE A SPINDLER 

LINEBARGER GOGGAN BLAIR & 

SAMPSON, LLP 2777 N. STEMMONS FRWY, 

STE 1000

DALLAS, TX 75207

TAXING DISTRICTS COLLECTED BY 

POTTER COUNTY

337 5/7/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$57,165.89 S $0.00 S

D'LAYNE CARTER P.O. BOX 9132

AMARILLO, TX 79105-9132

TAXING DISTRICTS COLLECTED BY 

POTTER COUNTY

651 1/29/2019 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$50,561.90 A $0.00 A

D'LAYNE CARTER PO BOX 9132

AMARILLO, TX 79105-9132

Page 7 of 9 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 58 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Tax Claims - Paid by Debtor

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 5

Second Omnibus Objection

THE WOODLANDS METRO CENTER MUD 20 4/6/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$2,890.91

$0.00

S

P

$0.00

$0.00

S

MICHAEL J. DARLOW 1235 NORTH LOOP P

WEST SUITE 600

HOUSTON, TX 77008

THE WOODLANDS ROAD UTILITY 

DISTRICT # 1

2 4/6/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$5,919.47 S $0.00 S

MICHAEL J. DARLOW 1235 NORTH LOOP 

WEST SUITE 600

HOUSTON, TX 77008

TOWNSHIP OF WAYNE 536 11/12/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$21,231.38 S $0.00 S

DORSEY & SEMRAU, LLC ROBERT J. 

ROSSMEISSL 714 MAIN STREET P.O. BOX 

228

BOONTON, NJ 07005

TYLER INDEPENDENT SCHOOL DISTRICT 639 1/18/2019 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$38,134.27 S $0.00 S

C/O TAB BEALL, PERDUE BRANDON ET 

AL. PO BOX 2007

TYLER, TX 75710-2007

VENTURA COUNTY TAX COLLECTOR 647 1/28/2019 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$32,362.16 S $0.00 S

ATTN: BANKRUPTCY 800 S VICTORIA AVE

VENTURA, CA 93009-1290

WICHITA COUNTY 235 6/25/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$40,533.01 S $0.00 S

C/O PERDUE, BRANDON, FIELDER, 

COLLINS & MOTT, LLP ATTN: JEANMARIE 

BAER PO BOX 8188

WICHITA FALLS, TX 76307

WICOMICO COUNTY, MARYLAND 456 10/29/2018 TRU 2005 RE II Trust

18-31432

Taxes being paid by debtor as they 

become due.

$25,141.72 S $0.00 S

FINANCE OFFICE PO BOX 4036

SALISBURY, MD 21803

Page 8 of 9 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 59 of 66
Claimant Name and Address Claim # Claim Date Amount * Class

Toys "R" Us Property Company I, LLC

Debtor

Tax Claims - Paid by Debtor

Claim

Amount * Class

Modified Claim

Reason for Modification

SCHEDULE 5

Second Omnibus Objection

YAKIMA COUNTY TREASURER 649 6/14/2018 TRU 2005 RE I, LLC

18-31431

Taxes being paid by debtor as they 

become due.

$16,155.72 A $0.00 A

PO BOX 22530

YAKIMA, WA 98907

YAKIMA COUNTY TREASURER 196 6/14/2018 Toys "R" Us Property 

Company I, LLC

18-31429

Taxes being paid by debtor as they 

become due.

$16,155.72 S $0.00 S

PO BOX 22530

YAKIMA, WA 98907

Totals for 60 Claims $3,918,981.84 $0.00

Page 9 of 9 Prepared by Province, Inc.

Class Key: A - Administrative, P - Priority, S - Secured, U - Unsecured, K - Unknown

* Plus, in certain instances, additional contingencies, unliquidated amounts, interest, penalties, and/or fees.

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 60 of 66
Exhibit B 

Atkinson Declaration 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 61 of 66
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 Hill Street Properties LLC

 IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

)

In re: ) Chapter 11 

)

TOYS “R” US PROPERTY COMPANY I, LLC, et al.1

) Case No. 18-31429 (KLP) 

)

Debtors. ) (Jointly Administered) 

)

DECLARATION OF MICHAEL ATKINSON IN SUPPORT OF HILL STREET 

PROPERTIES LLC’S SECOND OMNIBUS OBJECTION TO CERTAIN (A) REDUCED 

CLAIMS, (B) INSUFFICIENT DOCUMENTATION CLAIMS, (C) SATISFIED LEASE 

CLAIMS, (D) NO LIABILITY CLAIMS, AND (E) SATISFIED TAX CLAIMS 

I, Michael Atkinson, hereby declare under penalty of perjury: 

1. I am a Principal with Province, Inc. (“Province”), a restructuring advisory services 

firm with numerous offices throughout the country.2 I, along with my colleagues at Province, have 

been engaged by Hill Street Properties LLC (“Hill Street”) to provide various restructuring and 

financial services. In my current position with Hill Street, I am responsible for all claims 

management related matters. I am generally familiar with the Propco I Debtors’ day-to-day 

operations, financing arrangements, business affairs, and books and records that reflect, among 

1

 The debtors in these chapter 11 cases, Toys “R” Us Property Company I, LLC. and its debtor affiliates 

(collectively, the “Propco I Debtors”) along with the last four digits of each Propco I Debtor’s federal tax 

identification number, are set forth in the Final Order (I) Directing Joint Administration of Hill Street’ Chapter 

11 Cases and (II) Granting Related Relief [Docket No. 94]. 

2

 Capitalized terms used but not otherwise defined in this Declaration have the meanings given to them in the 

Objection. 

Case 18-31429-KLP Doc 1332 Filed 03/21/19 Entered 03/21/19 14:39:55 Desc Main

 Document Page 62 of 66
2 

other things, the Propco I Debtors’ liabilities and the amount thereof owed to their creditors as of 

the Petition Date. I am above 18 years of age, and I am competent to testify. 

2. I submit this declaration (this “Declaration”) in support of Hill Street Properties 

LLC’s Second Omnibus Objection to Certain (A) Reduced Claims, (B) Insufficient Documentation 

Claims, (C) Satisfied Lease Claims, (D) No Liability Claims, and (E) Satisfied Tax Claims

(the “Objection”) and am directly, or by and through the Hill Street’s advisors and personnel, 

familiar with the information contained therein and the exhibits and schedules attached thereto. I 

am authorized to submit this declaration on Hill Street’s behalf. Except as otherwise indicated, all 

facts set forth in this Declaration are based upon my personal knowledge of the Propco I Debtors’ 

operations and finances, information learned from my review of relevant documents, and 

information I have received from other members of the Hill Street’s management, Hill Street’s 

employees or Hill Street’s advisors. As to matters regarding state and federal law, including 

bankruptcy law, I have relied on the advice of counsel. If I were called upon to testify, I could and 

would testify competently to the facts set forth in this Declaration on that basis. 

3. To the best of my knowledge, information, and belief, insofar as I have been able 

to ascertain after reasonable inquiry, considerable time and resources have been expended to 

ensure a high level of diligence in reviewing and reconciling the proofs of claim filed against the 

Propco I Debtors in the chapter 11 cases. In evaluating the Disputed Claims, Hill Street and/or its 

advisors have thoroughly reviewed the Propco I Debtors’ books and records and the relevant 

proofs of claim, as well as the supporting documentation provided by each claimant, if any, and 

have determined that each Disputed Claim should be modified or disallowed and expunged as set 

forth in the Objection. As such, I believe that the modification or expungement and disallowance 

of the Disputed Claims on the terms set forth in the Objection is appropriate. 

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I. Reduced Amount Claims

4. To the best of my knowledge, information, and belief, Hill Street and/or its 

professionals have determined that the Proofs of Claim listed on Schedule 1 to the Order do not 

accurately reflect current amounts owed by the Propco I Debtors according to their books and 

records. After carefully reviewing the Reduced Amount Claims in good faith, utilizing due 

diligence by appropriate personnel, I believe that each of Reduced Amount Claims should be 

reduced to have the claim amounts depicted in the “Modified Claim” column of Schedule 1 to the 

Order. Failure to modify such Proofs of Claim could result in the relevant claimants receiving a 

better recovery than other similarly situated creditors, even though such recovery is not warranted. 

As such, I believe the reduction of the Reduced Amount Claims on the terms set forth in the 

Objection is appropriate. 

II. Insufficient Documentation Claims

5. To the best of my knowledge, information, and belief, Hill Street and/or its advisors 

have determined that the Proofs of Claim listed on Schedule 2 to the Order do not provide 

sufficient information to enable the Hill Street to determine whether or not such claim may be 

valid, and, therefore, do not represent valid Proofs of Claim against the Propco I Debtors’ estates. 

If the Insufficient Documentation Claims are not disallowed and expunged, the relevant claimants 

may be improperly paid on account of interests that do not exist. As such, I believe the 

disallowance and expungement of the Insufficient Documentation Claims on the terms set forth in 

the Objection are appropriate. 

III. Satisfied Lease Claims 

6. To the best of my knowledge, information, and belief, Hill Street and/or its advisors 

have determined that, based on its review of the Proofs of Claim and a thorough analysis of the 

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Propco I Debtors’ books and records, the Satisfied Lease Claims identified on Schedule 3 to the 

Order have been paid or otherwise settled and the Propco I Debtors no longer have any outstanding 

liabilities associated therewith. Failure to disallow and expunge the Satisfied Lease Claims could 

result in the applicable claimants receiving multiple recoveries against the Propco I Debtors’ 

estates, to the detriment of other similarly situated creditors. Moreover, elimination of the Satisfied 

Lease Claims will enable Hill Street to maintain a more accurate claims register. As such, I believe 

the disallowance and expungement of the Satisfied Lease Claims on the terms set forth in the 

Objection is appropriate. 

IV. No Liability Claims 

7. To the best of my knowledge, information, and belief, Hill Street and/or its 

professionals have determined that the Proofs of Claim listed on Schedule 4 to the Order do not 

accurately reflect amounts owed by the Propco I Debtors according to a thorough analysis of the 

Propco I Debtors’ books and records, and, therefore, do not represent valid Proofs of Claim against 

the Propco I Debtors’ estates. Failure to disallow and expunge the No Liability Claims could result 

in the relevant claimants receiving an unwarranted recovery against the Propco I Debtors to the 

detriment of other similarly situated creditors. As such, I believe the disallowance and 

expungement of the No Liability Claims on the terms set forth in the Objection is appropriate. 

V. Satisfied Lease Claims 

8. To the best of my knowledge, information, and belief, Hill Street and/or its advisors 

have determined that, based on its review of the Proofs of Claim and a thorough analysis of the 

Propco I Debtors’ books and records, the Satisfied Tax Claims identified on Schedule 5 to the 

Order have been paid or otherwise settled and the Propco I Debtors no longer have any outstanding 

liabilities associated therewith. Failure to disallow and expunge the Satisfied Tax Claims could 

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result in the applicable claimants receiving multiple recoveries against the Propco I Debtors’ 

estates, to the detriment of other similarly situated creditors. Moreover, elimination of the Satisfied 

Tax Claims will enable Hill Street to maintain a more accurate claims register. As such, I believe 

the disallowance and expungement of the Satisfied Tax Claims on the terms set forth in the 

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing 

statements are true and correct to the best of my knowledge, information, and belief. 

Dated: March 21, 2019 Respectfully submitted, 

/s/ Michael Atkinson 

Michael Atkinson, Principal 

Province, Inc. 

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