COOLEY LLP 

Cullen D. Speckhart (VSB 79096)

Olya Antle (VSB 83153)

1299 Pennsylvania Avenue, NW, Suite 700

Washington, DC 20004-2400

Telephone: (202) 842-7800

Facsimile: (202) 842-7899

Counsel to the Plan Administrator

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

)

In re: ) Chapter 11

)

RETAIL GROUP, INC., et al.,

1

) Case No. 20-33113 (KRH)

)

Reorganized Debtors. ) (Jointly Administered)

)

CERTIFICATION OF NO OBJECTION REGARDING THE PLAN 

ADMINISTRATOR’S THIRTY-FIRST OMNIBUS OBJECTION TO CLAIMS 

(NO LIABILITY LEASE CLAIMS AND PARTIALLY SATISFIED LEASE CLAIMS) 

The undersigned hereby certifies as follows: 

 On July 27, 2021, Jackson Square Advisors LLC, in its capacity as the plan administrator of 

the above-captioned reorganized debtors (the “Plan Administrator”) filed The Plan Administrator’s 

Thirty-First Omnibus Objection to Claims (No Liability Lease Claims and Partially Satisfied Lease 

Claims) [Docket No. 2333] (the “Objection”) with the United States Bankruptcy Court for the Eastern 

District of Virginia (the “Court”). 

On July 27, 2021, the Plan Administrator filed the Notice of the Plan Administrator’s ThirtyFirst Omnibus Objection to Claims (the “Notice”) [Docket No. 2338] with the Court and caused the 

Objection and Notice to be served on all necessary parties. 

1

 A complete list of each of the Reorganized Debtors in these chapter 11 cases may be obtained on the website of 

the Reorganized Debtors’ claims and noticing agent at http://cases.primeclerk.com/ascena. The location of 

Reorganized Debtor Mahwah Bergen Retail Group, Inc.’s principal place of business and the Reorganized 

Debtors’ service address in these chapter 11 cases is 933 MacArthur Boulevard, Mahwah, New Jersey 07430. 

Case 20-33113-KRH Doc 2409 Filed 09/03/21 Entered 09/03/21 19:40:28 Desc Main

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 Pursuant to the procedures set forth in the Order (I) Establishing Certain Notice, Case 

Management and Administrative Procedures, and (II) Granting Related Relief [Docket No. 79] and 

the Notice, any pleadings responsive to the Objection had to be filed and served no later than August 

17, 2021 (the “Response Deadline”). In the absence of any timely responses, the Plan Administrator 

may submit a proposed order to the Court granting the relief requested without further notice or a 

hearing. 

 The Plan Administrator received several informal responses from certain claimants whose 

claims are subject to the Objection. The Plan Administrator is working to resolve these responses with 

the claimants and has excluded the unresolved claims from the revised proposed order sustaining the 

Objection [Docket No. 2408]. Upon resolution of the unresolved claims, the Plan Administrator will 

file supplemental order(s) with respect to the Objection, as applicable. 

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Other than the aforementioned responses, the undersigned is not aware of any responsive 

pleadings concerning the Objection. Accordingly, an order sustaining the Objection shall be submitted 

to the Court for entry. 

Dated: September 3, 2021

/s/ Olya Antle

COOLEY LLP

Cullen D. Speckhart (VSB 79096) 

Olya Antle (VSB 83153) 

1299 Pennsylvania Avenue, NW, Suite 700 

Washington, DC 20004-2400 

Telephone: (202) 842-7800 

Facsimile: (202) 842-7899 

Email: cspeckhart@cooley.com 

 oantle@cooley.com 

Counsel to the Plan Administrator

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