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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)

)

THE PLAN ADMINISTRATOR’S THIRTY-FIRST 

OMNIBUS OBJECTION TO CLAIMS 

(NO LIABILITY LEASE CLAIMS AND 

PARTIALLY SATISFIED LEASE CLAIMS) 

Jackson Square Advisors LLC, in its capacity as the Plan Administrator of the abovecaptioned reorganized debtors and debtors-in-possession (collectively, the “Debtors”), respectfully 

states as follows in support of this omnibus objection to claims (the “Objection”):2

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 

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. 

2

 A detailed description of the Debtors, their business, and the facts and circumstances supporting these chapter 11 

cases is set forth in the Declaration of Carrie W. Teffner, Interim Executive Chair of Ascena Retail Group, Inc., 

in Support of Chapter 11 Petitions and First Day Motions [Docket No. 14] (the “First Day Declaration”). 

Capitalized terms used but not defined herein shall have the meanings given to them in the First Day Declaration. 

PARTIES RECEIVING THIS OBJECTION SHOULD 

REVIEW SCHEDULES 1–2 TO THE PROPOSED ORDER TO 

DETERMINE IF THEIR CLAIM IS SUBJECT TO THIS OBJECTION. 

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Relief Requested 

1. The Plan Administrator seeks entry of an order, substantially in the form attached 

hereto as Exhibit A (the “Order”) disallowing, expunging, and/or modifying the portion of each 

Proof of Claim (as defined herein), as applicable, identified on Schedules 1–2 to Exhibit A

(collectively, the “Disputed Claims”) only to the extent set forth therein and summarized as 

follows: 

 Disallowing and expunging each Proof of Claim identified on Schedule 1 to Exhibit A

arising from certain of the Debtors’ non-residential real property leases because the Plan 

Administrator has determined that, based on the Debtors’ Books and Records (as defined 

herein), the Debtors have no liability for such claims (the “No Liability Lease Claims”); 

and 

 Disallowing, expunging, and modifying the portion of each Proof of Claim identified on 

Schedule 2 to Exhibit A arising from certain of the Debtors’ non-residential real property 

leases in the column titled “Modified Claims” to the extent that such portion (the 

“Administrative Portion”) constitutes an administrative expense claim for postpetition 

lease charges that have either been previously satisfied or for which the Debtors have no 

liability because such charges relate to executory contracts that the Debtors assumed and 

assigned (the “Partially Satisfied Lease Claims”).3 

2. In support of this Objection, the Plan Administrator submits the Declaration of Rob 

Esposito in Support of the Plan Administrator’s Thirty-First Omnibus Objection to Claims (No 

Liability Lease Claims and Partially Satisfied Lease Claims) (the “Esposito Declaration”) attached 

hereto as Exhibit B. This Objection complies in all respects with Rule 3007-1 of the Local Rules 

of the United States Bankruptcy Court for the Eastern District of Virginia (the “Local Bankruptcy 

Rules”). 

3

 For the avoidance of doubt, pursuant to this Objection, the Plan Administrator solely objects to the Administrative 

Portion of each Partially Satisfied Lease Claim identified on Schedule 2 to Exhibit A and seeks to leave the 

remaining portion of such Partially Satisfied Lease Claims unaffected, with all parties’ rights reserved. 

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Jurisdiction and Venue 

3. 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 August 15, 1984. The Plan Administrator confirms its 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 Objection to the extent that it is later determined 

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

herewith consistent with Article III of the United States Constitution. 

4. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

5. The bases for the relief sought herein are sections 502(b) and 503(b) of title 11 of 

the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), Bankruptcy Rules 3003 

and 3007, and Local Bankruptcy Rule 3007-1. 

Background 

6. On July 23, 2020 (the “Petition Date”), each of the Debtors filed a voluntary 

petition for relief under chapter 11 of the Bankruptcy Code. 

7. On August 3, 2020, the United States Trustee for the Eastern District of Virginia 

(the “U.S. Trustee”) appointed an official committee of unsecured creditors [Docket No. 164]. 

8. On August 27, 2020, the 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. 453] (the “Bar Date Order”) 

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establishing September 30, 2020 at 4:00 p.m. (prevailing Eastern Time) (the “Claims Bar Date”),4

as the final date and time for all persons and entities holding claims against the Debtors that arose 

or are deemed to have arisen prior to the commencement of these cases on the Petition Date to file 

proofs of claim in these chapter 11 cases (collectively, “Proofs of Claim,” and each a “Proof of 

Claim”). The Claims Bar Date generally applies to all types of claims against the Debtors that 

arose prior to the Petition Date, including secured claims, unsecured priority claims, unsecured 

non-priority claims, and claims entitled to priority under section 503(b)(9) of the Bankruptcy 

Code.5 Notice of the Claims Bar Date was provided by mail and publication in accordance with 

the procedures outlined in the Bar Date Order. 

9. On July 24, 2020, the Court entered an order [Docket No. 69] authorizing the 

retention of Prime Clerk LLC as claims and noticing agent (the “Claims Agent”). As such, Prime 

Clerk is to, among other things, receive, maintain, docket, and otherwise administer Proofs of 

Claim filed in the Debtors’ chapter 11 cases. 

10. On August 27, 2020, the Debtors filed their schedules of assets and liabilities 

(the “Schedules”) and statements of financial affairs (the “Statements” and, together with the 

Schedules, as amended, modified, or supplemented, the “Schedules and Statements”) [Docket Nos. 

6–8, 467–468]. 

4

 Pursuant to the Bar Date Order, unless otherwise ordered by the Court, the bar date for filing claims arising from 

the rejection of executory contracts and unexpired leases of the Debtors is the later of (i) the General Claims Bar 

Date or the Governmental Bar Date, as applicable, and (ii) 4:00 p.m., prevailing Eastern time, on the date that is 

30 days after the later of (A) entry of an order approving the rejection of any executory contract or unexpired 

lease of the Debtors or (B) the effective date of a rejection of any executory contract or unexpired lease of the 

Debtors pursuant to operation of any Court order. 

5

 The Bar Date Order also established January 19, 2021, at 4:00 p.m. (prevailing Eastern Time) as the final date 

and time for all governmental units (as defined in section 101(27) of the Bankruptcy Code) holding claims against 

the Debtors that arose or are deemed to have arisen prior to the commencement of these cases on the Petition Date 

to file Proofs of Claim in these chapter 11 cases. 

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11. On February 24, 2021, the Debtors filed an Amended Joint Chapter 11 Plan 

(Technical Modifications) of Mahwah Bergen Retail Group, Inc. (f/k/a Ascena Retail Group, Inc.) 

and Its Debtor Affiliates (the “Plan”) [Docket No. 1794]. On February 25, 2021, the Court entered 

the Order Confirming the Amended Joint Chapter 11 Plan (Technical Modifications) of Mahwah 

Bergen Retail Group, Inc. (f/k/a Ascena Retail Group, Inc.) and Its Debtor Affiliates (the 

“Confirmation Order”) [Docket No. 1811]. 

12. Pursuant to the Plan, Confirmation Order, and Plan Administration Agreement 

[Docket No. 1790, Ex. H], Jackson Square Advisors LLC was appointed as the Plan Administrator 

and sole representative of the Debtors upon occurrence of the Effective Date. On March 5, 2021, 

the Debtors filed a Notice of Occurrence of the Plan Effective Date [Docket No. 1845]. 

13. In the ordinary course of business, the Debtors maintained books and records 

(the “Books and Records”) that reflected, among other things, the nature and amount of the 

liabilities owed to their creditors as of the Petition Date. As part of these chapter 11 cases, the 

Debtors filed their Schedules and Statements reflecting the obligations owed to their creditors as 

of the Petition Date. To date, approximately 6,450 Proofs of Claim asserting more than 

$1,750,260,000 in aggregated amounts have been filed, including a number of Proofs of Claim for 

administrative expense and priority claims. The Plan Administrator and its advisors have been 

engaging in a systematic review of the Proofs of Claim, working diligently to review, compare, 

and reconcile the Proofs of Claim against the Debtors’ Books and Records. Because of the number 

of claims in these cases, the Debtors sought and were granted approval to file omnibus objections 

to certain claims in accordance with the procedures set forth in the Order Approving Omnibus 

Claims Objection Procedures and Filing of Substantive Omnibus Claims Objections [Docket No. 

1387] (the “Objection Procedures”). 

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Basis for Objection 

14. 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 . . . 

objects.” 11 U.S.C. § 502(a). The burden of proof for determining the validity of claims rests on 

different parties at different stages of the claims-objection process. As explained by the United 

States Court of Appeals for the Third Circuit: 

The burden of proof for claims brought in the bankruptcy court 

under 11 U.S.C.A. § 502(a) rests on different parties at different 

times. Initially, the claimant must allege facts sufficient to support 

the claim. If the averments in his filed claim meet this standard of 

sufficiency, it is ‘prima facie’ valid [citations omitted]. In other 

words, a claim that alleges facts sufficient to support legal liability 

to the claimant satisfies the claimants’ initial obligation to go 

forward. The burden of going forward then shifts to the objector to 

produce evidence sufficient to negate the prima facie validity of the 

filed claim. . . . In practice, the objector must produce evidence 

which, if believed, would refute at least one of the allegations that 

is essential to the claim’s legal sufficiency. If the objector produces 

sufficient evidence to negate one or more of the sworn facts in the 

proof of claim, the burden reverts to the claimant to prove the 

validity of the claim by a preponderance of the evidence. 

In re Allegheny Int’l Inc., 954 F.2d 167, 173–74 (3d Cir. 1992) (citation omitted). Once the prima 

facie validity of a claim is rebutted, the burden shifts back to the claimant to prove the validity of 

his or her claim by a preponderance of the evidence. Id. at 173. The burden of persuasion is 

always on the claimant. Id. Bankruptcy Rule 3007(d) permits a debtor to join objections to more 

than one claim in an omnibus objection if such objections are based on enumerated non-substantive 

grounds. See FED. R. BANKR. P. 3007(d)(1). 

A. No Liability Lease Claims 

15. Upon review of the Proofs of Claim filed against the Debtors in these chapter 11 

cases, the Plan Administrator has identified 50 No Liability Lease Claims listed on Schedule 1

annexed to Exhibit A, in the aggregate claimed amount of $1,136,594.59. The Plan Administrator 

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objects to these claims. The Plan Administrator has determined that the No Liability Lease Claims 

do not accurately reflect amounts owed by the Debtors according to their Books and Records. 

Instead, the Plan Administrator asserts that the Debtors have no liability for such Proofs of Claim. 

The administrative liabilities asserted in the No Liability Lease Claims are (1) for postpetition 

lease charges that have been satisfied in the ordinary course of the Debtors’ business through the 

applicable rejection date for each of the underlying leases; (2) are for postpetition lease charges 

pursuant to leases that have been assumed and assigned to Premium Brands Opco LLC; or (3) are 

made on account of leases with Maurices Incorporated, a non-Debtor entity. As a result, the Plan 

Administrator is seeking entry of the Order disallowing and expunging the No Liability Lease 

Claims in their entirety, as identified on Schedule 1 to Exhibit A. Failure to disallow and expunge 

the No Liability Lease Claims could result in the applicable claimants receiving undue recoveries 

against the Debtors’ estates, to the detriment of other similarly situated creditors. Moreover, 

elimination of the No Liability Lease Claims will enable the Plan Administrator to maintain a more 

accurate claims register. Accordingly, the Plan Administrator requests that the Court enter the 

Order, disallowing and expunging the No Liability Lease Claims identified on Schedule 1 to 

Exhibit A. 

B. Partially Satisfied Lease Claims 

16. Upon review of the Proofs of Claim filed against the Debtors in these chapter 11 

cases, the Plan Administrator has identified 24 Partially Satisfied Lease Claims listed on Schedule 

2 annexed to Exhibit A, in the aggregate claimed amount of $8,350,089.51. The Plan 

Administrator objects solely to the Administrative Portion of the Partially Satisfied Lease Claims 

in the aggregate claimed amount of $455,572.14. The Plan Administrator has determined that the 

Administrative Portion of each such Claim has either been previously satisfied during these chapter 

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11 cases or relates to executory contracts that the Debtors assumed and assigned. Failure to reduce 

the Partially Satisfied Lease Claims by the amount of the respective Administrative Portion of such 

Claims could result in each relevant claimant receiving an unwarranted recovery against the 

Debtors’ estates, to the detriment of other similarly situated creditors. Accordingly, the Plan 

Administrator requests that the Court enter the Order reducing the amount of each Partially 

Satisfied Lease Claim as indicated by the amounts identified in the “Modified Claims” column on 

Schedule 2 to Exhibit A. 

17. Any disallowance or expungement of the Administrative Portion of the Partially 

Satisfied Lease Claims will not affect the unsecured portion of the Proofs of Claim set forth under 

the column heading “Modified Claims,” which will remain on the claims register unless withdrawn 

by the applicable claimants or disallowed by the Court, subject to the Plan Administrator’s right 

to object to each of the Proofs of Claim or Modified Claims on any other grounds that the Plan 

Administrator discovers or elects to pursue. 

Separate Contested Matters 

18. To the extent that a response is filed regarding any Disputed Claim identified in 

this Objection and the Plan Administrator is unable to resolve the response, the objection by the 

Plan Administrator to each such Disputed Claim asserted herein shall constitute a separate 

contested matter as contemplated by Bankruptcy Rule 9014. Any order entered by the Court 

regarding an objection asserted in this Objection shall be deemed a separate order with respect to 

each such Disputed Claim. 

Reservation of Rights 

19. 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 Debtors under the Bankruptcy Code 

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or other applicable nonbankruptcy law; (b) a waiver of the Plan Administrator’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) a request or authorization to assume, adopt, or reject any agreement, contract, or lease 

pursuant to section 365 of the Bankruptcy Code; (f) an admission as to the validity, priority, 

enforceability, or perfection of any lien on, security interest in, or other encumbrance on property 

of the Debtors’ estates; or (g) a waiver of any claims or causes of action which may exist against 

any entity under the Bankruptcy Code or any other applicable law. If the Court grants the relief 

sought herein, any payment made pursuant to the Court’s order is not intended and should not be 

construed as an admission as to the validity, priority, or amount of any particular claim or a waiver 

of the Plan Administrator’s or any other party in interest’s right to subsequently dispute such claim. 

20. The Plan Administrator hereby reserves its right to amend, modify, and supplement 

this Objection, including to object to any of the Disputed Claims listed on Schedules 1–2 annexed 

to Exhibit A, on any additional grounds, prior to the hearing before the Court on this Objection, 

if any; provided that nothing in this Objection shall affect the Plan Administrator’s right to object 

to the Disputed Claims or any other Proofs of Claim at a future date on a basis other than as set 

forth in this Objection as permitted by bankruptcy or nonbankruptcy law, subject to any limitations 

set forth in the Local Bankruptcy Rules. 

Statement of Compliance with Local Bankruptcy Rule 3007-1

21. Counsel to the Plan Administrator has reviewed the requirements of Local 

Bankruptcy Rule 3007-1 and certifies that this Objection substantially complies with such Local 

Bankruptcy Rule. To the extent that the Objection does not comply in all respects with the 

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requirements of Local Bankruptcy Rule 3007-1, the Plan Administrator believes such deviations 

are not material and respectfully request that any such requirement be waived. 

Notice

22. The Plan Administrator will provide notice of this Objection via first class mail, 

facsimile or email (where available) upon the parties identified in paragraph 141 of the 

Confirmation Order and in accordance with the Objection Procedures. The Plan Administrator 

submits that, in light of the nature of the relief requested, no other or further notice need be given. 

WHEREFORE, the Plan Administrator respectfully requests that the Court enter the Order

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

circumstances.

Dated: July 27, 2021

/s/ Cullen D. Speckhart

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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Exhibit A 

Proposed Order

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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)

)

ORDER SUSTAINING THE PLAN ADMINISTRATOR’S THIRTY-FIRST 

OMNIBUS OBJECTION TO CLAIMS 

(NO LIABILITY LEASE CLAIMS AND 

PARTIALLY SATISFIED LEASE CLAIMS) 

Upon the objection (the “Objection”)2 of Jackson Square Advisors LLC, in its capacity as 

the Plan Administrator of the above-captioned reorganized debtors and debtors-in-possession 

(collectively, the “Debtors”), for entry of an order (this “Order”), disallowing and expunging the 

portion of each Proof of Claim set forth on Schedules 1–2 attached hereto, all as more fully set 

forth in the Objection; and upon the Esposito Declaration; and this Court having 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 August 15, 1984; and that 

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 

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. 

2

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

No. ____]. 

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this Court may enter a final order consistent with Article III of the United States Constitution; and 

this Court having found that venue of this proceeding and the Objection in this district is proper 

pursuant to 28 U.S.C. §§ 1408 and 1409; and this Court having found that the relief requested in 

the Objection is in the best interests of the Debtors’ estates, their creditors, and other parties in 

interest; and this Court having found that the Plan Administrator’s notice of the Objection and 

opportunity for a hearing on the Objection were appropriate under the circumstances and no other 

notice need be provided; and this Court having reviewed the Objection; and this Court having 

determined that the legal and factual bases set forth in the Objection establish just cause for the 

relief granted herein; and upon all of the proceedings had before this Court; and after due 

deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT: 

1. The Objection is sustained as set forth herein. 

2. The No Liability Lease Claims set forth on the attached Schedule 1 are hereby 

disallowed and expunged in their entirety. 

3. The Administrative Portion of each of the Partially Satisfied Lease Claims set forth 

on the attached Schedule 2 is hereby disallowed and expunged; provided that this Order will not 

affect the unsecured amounts identified on Schedule 2 attached hereto in the column titled 

“Modified Claims.” All parties’ rights are reserved with respect to the Modified Claims, including 

the Plan Administrator’s right to file a further objection and seek disallowance thereof and the 

GUC Trust’s right to object to the unsecured amounts identified on Schedule 2. 

4. The Plan Administrator’s objection to the Disputed Claims addressed in the 

Objection constitutes a separate contested matter as contemplated by Bankruptcy Rule 9014. This 

Order shall be deemed a separate order with respect to each claim. Any stay of this Order pending 

appeal by any claimant subject to this Order shall only apply to the contested matter that involves 

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such claimant and shall not act to stay the applicability or finality of this Order with respect to the 

other contested matters covered hereby. 

5. Nothing in this Order shall affect the Plan Administrator’s right to object to any of 

the Modified Claims or any other Proofs of Claim at a future date. 

6. The Claims Agent is authorized and directed to modify the claims register in 

accordance with entry of the relief granted in this Order. 

7. Notwithstanding the relief granted in this Order and any actions taken pursuant to 

such relief, nothing in this Order shall be deemed: (a) an admission as to the validity, priority, or 

amount of any particular claim against a Debtor entity; (b) a waiver of the Plan Administrator’s or 

any other party in interest’s right to dispute any particular claim on any grounds; (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 Order or the Objection; (e) a request or authorization to 

assume any agreement, contract, or lease pursuant to section 365 of the Bankruptcy Code; (f) a 

waiver or limitation of the Plan Administrator’s or any other party in interest’s rights under the 

Bankruptcy Code or any other applicable law; or (g) a concession by the Plan Administrator or 

any other party in interest that any liens (contractual, common law, statutory, or otherwise) 

satisfied pursuant to this Order are valid and the Plan Administrator and all other parties in interest 

expressly reserve their rights to contest the extent, validity, or perfection or to seek avoidance of 

all such liens. Any payment made pursuant to this Order should not be construed as an admission 

as to the validity, priority, or amount of any particular claim or a waiver of the Plan Administrator’s 

or any other party in interest’s rights to subsequently dispute such claim. 

8. The Plan Administrator is authorized to take all actions necessary to effectuate the 

relief granted in this Order in accordance with the Objection. 

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

related to the implementation, interpretation, and enforcement of this Order. 

Dated: __________

Richmond, Virginia United States Bankruptcy Judge

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WE ASK FOR THIS:

/s/ Cullen D. Speckhart 

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

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/ Cullen D. Speckhart 

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Schedule 1 

No Liability Lease Claims

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NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

1 156 FIFTH AVENUE CORP.

C/O SPOTTS FAIN PC

411 E. FRANKLIN ST., STE. 600

RICHMOND, VA 23219

2/18/2021 20-33122 (KRH) Ann, Inc. 6204 $ 32,289.54*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

2 156 FIFTH AVENUE CORP.

C/O SPOTTS FAIN PC

411 E. FRANKLIN ST., STE. 600

RICHMOND, VA 23219

2/18/2021 20-33132 (KRH) AnnTaylor Retail, Inc. 6194 $ 32,289.54*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

3 171 EAST 84TH OWNERS LLC

C/O PATRICK MILNER

GARAGE MANAGEMENT COMPANY

770 LEXINGTON AVE, 11TH FLOOR

NEW YORK, NY 10065

3/12/2021 20-33132 (KRH) AnnTaylor Retail, Inc. 6281 $ 46,475.41

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

4 171 EAST 84TH OWNERS, LLC

C/O CHAPMAN CONSULTING LLC

770 LEXINGTON AVENUE 11TH FLOOR

NEW YORK, NY 10065

1/19/2021 20-33132 (KRH) AnnTaylor Retail, Inc. 5840 $ 36,501.00

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

5 ARCP MT ABILENE TX, LLC

C/O KUTAK ROCK LLP

ATTN: LISA M. PETERS, ESQ.

1650 FARNAM STREET

OMAHA, NE 68102

1/19/2021 20-33154 (KRH) Lane Bryant, Inc. 5641 $ 474.14

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

6 ARCP MT BOWLING GREEN KY, LLC

C/O KUTAK ROCK LLP

ATTN: LISA M. PETERS

1650 FARNAM STREET

OMAHA, NE 68102

1/19/2021 20-33154 (KRH) Lane Bryant, Inc. 5674 $ 187.06

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

* Indicates claim contains unliquidated and/or undetermined amounts Page 1 of 9

Retail Group, Inc. 20-33113 (KRH)

Thirty-First Omnibus Claims Objection

Schedule 1 - No Liability (Lease) Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 18 of 37
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

7 ARCP MT LAWTON OK, LLC

C/O KUTAK ROCK LLP

ATTN: LISA M. PETERS, ESQ.

1650 FARNAM STREET

OMAHA, NE 68102

1/19/2021 20-33154 (KRH) Lane Bryant, Inc. 5615 $ 200.53

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

8 ARCP MT MONROE LA, LLC

C/O KUTAK ROCK LLP

ATTN: LISA M. PETERS

1650 FARNAM STREET

OMAHA, NE 68102

1/19/2021 20-33154 (KRH) Lane Bryant, Inc. 5604 $ 246.42

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

9 BELDEN PARK DELAWARE, LLC

C/O ROBERT L. STARK ENTERPRISES, INC.

629 EUCLID AVE, SUITE 1300

CLEVELAND, OH 44114

1/18/2021 20-33170 (KRH) Tween Brands, Inc. 5474 $ 14,055.56

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

10 BRANDON SHOPPING CENTER PARTNERS LTD.

C/O BARCLAY DAMON, LLP

ATTN: NICLAS A. FERLAND, ESQ.

545 LONG WHARF DRIVE, 9TH FLOOR

NEW HAVEN, CT 06511

1/14/2021 20-33170 (KRH) Tween Brands, Inc. 5314 $ 880.79

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

11 BRE THRONE GARNER TOWNE SQUARE LP

C/O BALLARD SPAHR LLP

ATTN: LESLIE C. HEILMAN, ESQ.

919 N. MARKET STREET, 11TH FLOOR

WILMINGTON, DE 19801

1/19/2021 20-33154 (KRH) Lane Bryant, Inc. 5675 $ 185.91

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

12 CAMDEN VILLAGE LLC

C/O LA PIETRA AND NERLAND

GREGORY NERLAND

ONE KAISER PLAZA, SUITE 1015

OAKLAND, CA 94612

1/15/2021 20-33136 (KRH) Ascena Retail Holdings, Inc. 5399 $ 11,779.19

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

* Indicates claim contains unliquidated and/or undetermined amounts Page 2 of 9

Retail Group, Inc. 20-33113 (KRH)

Thirty-First Omnibus Claims Objection

Schedule 1 - No Liability (Lease) Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 19 of 37
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

13 CAPITAL AUGUSTA PROPERTIES LLC

GOULSTON & STORRS PC

C/O VANESSA P. MOODY

400 ATLANTIC AVENUE

BOSTON, MA 02110

1/18/2021 20-33154 (KRH) Lane Bryant, Inc. 5635 $ 4,631.35

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

14 CENTERTON SQUARE OWNERS, LLC

C/O MICHAEL S. AMATO, ESQ.

RUSKIN MOSCOU FALTISCHEK, P.C.

1425 RXR PLAZA

UNIONDALE, NY 11556-1425

1/19/2021 20-33170 (KRH) Tween Brands, Inc. 5643 $ 17,733.97

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

15 COLE MT RAPID CITY SD(I), LLC

C/O KUTAK ROCK LLP

ATTN: LISA M PETERS, ESQ.

1650 FARNAM STREET

OMAHA, NE 68102

1/19/2021 20-33170 (KRH) Tween Brands, Inc. 5601 $ 300.44

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

16 COLISEUM SHOPPES LP

JOHN R. HUMPHREY

TAFT STETTINIUS & HOLLISTER LLP

ONE INDIANA SQUARE

SUITE 3500

INDIANAPOLIS, IN 46204

1/13/2021 20-33158 (KRH) Catherines, Inc. 5251 $ 3,600.19

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

17 CPT CREEKSIDE TOWN CENTER, LLC

CLARK HILL PLC

C/O DAVID M. BLAU, ESQ.

151 S. OLD WOODWARD AVE., STE. 200

BIRMINGHAM, MI 48009

1/19/2021 20-33170 (KRH) Tween Brands, Inc. 5779 $ 10,683.02

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

18 CPT PEACHTREE FORUM I, LLC

C/O DAVID B. KITCHENS, ESQUIRE

KITCHENS KELLEY GAYNES P.C.

GLENRIDGE HIGHLANDS ONE, SUITE 800

5555 GLENRIDGE CONNECTOR

ATLANTA, GA 30342

3/23/2021 20-33132 (KRH) AnnTaylor Retail, Inc. 6312 $ 3,894.89

Reason: No liability exists on the Debtors' books and records. The liability relates to executory contracts which were assumed and assigned to Premium Brands Opco LLC.

* Indicates claim contains unliquidated and/or undetermined amounts Page 3 of 9

Retail Group, Inc. 20-33113 (KRH)

Thirty-First Omnibus Claims Objection

Schedule 1 - No Liability (Lease) Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 20 of 37
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

19 CTC GILBERT PHASE 1, L.L.C.

C/O BALLARD SPAHR LLP

ATTN: LESLIE C. HEILMAN, ESQ.

919 N. MARKET STREET, 11TH FLOOR

WILMINGTON, DE 19801

1/19/2021 20-33154 (KRH) Lane Bryant, Inc. 5753 $ 7,817.14

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

20 DEVIL'S LAKE ROAD, LLC

LOUIS F. SOLIMINE - THOMPSON HINE LLP

312 WALNUT STREET-14TH FLOOR

CINCINNATI, OH 45202

1/18/2021 20-33144 (KRH) Lane Bryant #6243, Inc. 5578 $ 7,010.22

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

21 EKLECCO NEWCO LLC

C/O BARCLAY DAMON LLP

ATTN: KEVIN M. NEWMAN

BARCLAY DAMON TOWER

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

1/15/2021 20-33154 (KRH) Lane Bryant, Inc. 5369 $ 484.35*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

22 EKLECCO NEWCO LLC

C/O BARCLAY DAMON LLP

ATTN: KEVIN M. NEWMAN

BARCLAY DAMON TOWER

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

1/15/2021 20-33170 (KRH) Tween Brands, Inc. 5372 $ 9.90*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

23 ENVISION USA (STL), LLC

C/O CKE PROPERTIES

1480 WOODSTONE DR., SUITE 215

ST.CHARLES, MO 63304

1/19/2021 20-33158 (KRH) Catherines, Inc. 5756 $ 1,071.47

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

24 FAIRLANE 28, LLC

C/O DAVID M. BLAU, ESQ.

CLARK HILL PLC

151 S. OLD WOODWARD AVE., STE. 200

BIRMINGHAM, MI 48009

1/19/2021 20-33158 (KRH) Catherines, Inc. 5883 $ 6,375.90

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

* Indicates claim contains unliquidated and/or undetermined amounts Page 4 of 9

Retail Group, Inc. 20-33113 (KRH)

Thirty-First Omnibus Claims Objection

Schedule 1 - No Liability (Lease) Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 21 of 37
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

25 FOX VALLEY MALL, LLC

BALLARD SPAHR LLP

C/O DUSTIN P. BRANCH, ESQ.

2029 CENTURY PARK EAST, SUITE 1400

LOS ANGELES, CA 90067-2915

1/19/2021 20-33154 (KRH) Lane Bryant, Inc. 5901 $ 26.06

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

26 FR FLORIDA, INC.

C/O BALLARD SPAHR LLP

ATTN: LESLIE C. HEILMAN, ESQ.

919 N. MARKET STREET, 11TH FL

WILMINGTON, DE 19801

1/19/2021 20-33170 (KRH) Tween Brands, Inc. 5833 $ 479.14

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

27 FR RIVERPOINT, LLC

C/O BALLARD SPAHR LLP

ATTN: LESLIE C. HEILMAN, ESQ.

919 N. MARKET STREET, 11TH FL.

WILMINGTON, DE 19801

1/19/2021 20-33170 (KRH) Tween Brands, Inc. 5725 $ 1.07

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

28 GALLERIA MALL INVESTORS, LP

C/O BALLARD SPAHR LLP

ATTN: LESLIE C. HEILMAN, ESQ.

919 N. MARKET STREET, 11TH FLOOR

WILMINGTON, DE 19801

2/19/2021 20-33132 (KRH) AnnTaylor Retail, Inc. 6205 $ 990.71

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

29 GARDEN CITY OWNER LLC

C/O VANESSA P. MOODY

GOULSTON & STORRS PC

400 ATLANTIC AVENUE

BOSTON, MA 02110

3/8/2021 20-33132 (KRH) AnnTaylor Retail, Inc. 6269 $ 10,220.36

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

30 GOVERNOR PLAZA ASSOCIATES

ATTN: LESLIE C. HEILMAN, ESQ.

C/O BALLARD SPAHR LLP

919 N. MARKET STREET, 11TH FLOOR

WILMINGTON, DE 19801

1/19/2021 20-33158 (KRH) Catherines, Inc. 5863 $ 4.71

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

* Indicates claim contains unliquidated and/or undetermined amounts Page 5 of 9

Retail Group, Inc. 20-33113 (KRH)

Thirty-First Omnibus Claims Objection

Schedule 1 - No Liability (Lease) Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 22 of 37
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

31 GREENWOOD PLACE COMMONS, LP

JOHN R. HUMPHREY

TAFT STETTINIUS & HOLLISTER LLP

ONE INDIANA SQUARE

SUITE 3500

INDIANAPOLIS, IN 46204

1/13/2021 20-33158 (KRH) Catherines, Inc. 5248 $ 2,764.23

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

32 HVTC, LLC

C/O BALLARD SPAHR LLP

ATTN: LESLIE C. HEILMAN, ESQ.

919 N. MARKET STREET, 11TH FLOOR

WILMINGTON, DE 19801

1/19/2021 20-33170 (KRH) Tween Brands, Inc. 5912 $ 5,190.12

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

33 IREIT FLOWOOD DOGWOOD, L.L.C.

C/O BARCLAY DAMON LLP

ATTN: KEVIN M. NEWMAN

BARCLAY DAMON TOWER

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

1/13/2021 20-33170 (KRH) Tween Brands, Inc. 5244 $ 703.15*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

34 IREIT WEST VALLEY CITY LAKE PARK, L.L.C.

C/O BARCLAY DAMON LLP

ATTN: KEVIN M. NEWMAN

BARCLAY DAMON TOWER

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

1/13/2021 20-33154 (KRH) Lane Bryant, Inc. 5252 $ 554.37*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

35 MN-CRYSTAL CENTER-QRX, LLC

C/O BARCLAY DAMON LLP

ATTN: KEVIN M. NEWMAN

BARCLAY DAMON TOWER

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

1/13/2021 20-33158 (KRH) Catherines, Inc. 5240 $ 220.42*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

* Indicates claim contains unliquidated and/or undetermined amounts Page 6 of 9

Retail Group, Inc. 20-33113 (KRH)

Thirty-First Omnibus Claims Objection

Schedule 1 - No Liability (Lease) Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 23 of 37
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

36 OLD ORCHARD URBAN LIMITED PARTNERSHIP

C/O BARCLAY DAMON, LLP

ATTN: NICLAS A. FERLAND, ESQ.

545 LONG WHARF DRIVE, 9TH FLOOR

NEW HAVEN, CT 06511

1/14/2021 20-33170 (KRH) Tween Brands, Inc. 5326 $ 1,367.71

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

37 PSLP LLC, A NEW JERSEY LIMITED LIABILITY COMPANY, SUCCESSOR BY 

MERGER TO PALMER SQUARE LIMITED PARTN

CLARK HILL PLC

C/O NELSON O. ROPKE

500 WOODWARD AVENUE

SUITE 3500

DETROIT, MI 48226

4/1/2021 20-33132 (KRH) AnnTaylor Retail, Inc. 6353 $ 1,744.04

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

38 PYRAMID WALDEN COMPANY, LP

C/O BARCLAY DAMON LLP

ATTN: KEVIN M. NEWMAN

BARCLAY DAMON TOWER

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

1/15/2021 20-33170 (KRH) Tween Brands, Inc. 5390 $ 379.73*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

39 RAMCO JACKSONVILLE LLC

C/O BARCLAY DAMON LLP

ATTN: KEVIN M NEWMAN

BARCLAY DAMON TOWER

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

1/19/2021 20-33158 (KRH) Catherines, Inc. 5897 $ 12,657.98*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

40 RLP DEVELOPMENT COMPANY

514 EAST VANDALIA

EDWARDSVILLE, IL 62025

2/12/2021 20-33113 (KRH) Ascena Retail Group, Inc. 6188 $ 13,854.18

Reason: No liability exists on the Debtors' books and records on account of a Maurices Incorporated lease. Maurices Incorporated is not a legal entity in this bankruptcy case.

* Indicates claim contains unliquidated and/or undetermined amounts Page 7 of 9

Retail Group, Inc. 20-33113 (KRH)

Thirty-First Omnibus Claims Objection

Schedule 1 - No Liability (Lease) Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 24 of 37
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

41 SALMON RUN SHOPPING CENTER, L.L.C.

C/O BARCLAY DAMON LLP

ATTN: KEVIN M. NEWMAN

BARCLAY DAMON TOWER

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

1/15/2021 20-33170 (KRH) Tween Brands, Inc. 5368 $ 362.32*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

42 SANGERTOWN SQUARE, L.L.C.

C/O BARCLAY DAMON LLP

ATTN: KEVIN M. NEWMAN

BARCLAY DAMON TOWER

125 EAST JEFFERSON STREET

SYRACUSE, NY 13202

1/15/2021 20-33170 (KRH) Tween Brands, Inc. 5391 $ 1,050.29*

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

43 SP PORTERS VALE, LLC

C/O BALLARD SPAHR LLP

ATTN: LESLIE C. HEILMAN, ESQ.

919 N. MARKET STREET, 11TH F

WILMINGTON, DE 19801

1/19/2021 20-33170 (KRH) Tween Brands, Inc. 5613 $ 222.31

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

44 STUYVESANT PLAZA

4 TOWER PLACE

SUITE 101

ALBANY, NY 12203

9/21/2020 20-33132 (KRH) AnnTaylor Retail, Inc. 1956 $ 774,229.85

Reason: No liability exists on the Debtors' books and records. The lease associated with this claim was assumed and assigned to Premium Brands Opco LLC.

45 TOWNE CENTER VENTURE, L.L.P.

2001 KIRBY DRIVE, SUITE 610

HOUSTON, TX 77019

1/19/2021 20-33158 (KRH) Catherines, Inc. 5782 $ 1,885.06

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

46 WPI - GRAND PLAZA SAN MARCOS, LLC

UAP - GRAND PLAZA, LLC

C/O NEWMARK MERRILL COMPANIES, INC.

ATTN: CATRINA BRANNON

427 COLLEGE BOULEVARD, SUITE K

OCEANSIDE, CA 92057

4/2/2021 20-33115 (KRH) Charming Shoppes, Inc. 6361 $ 6,813.01

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

* Indicates claim contains unliquidated and/or undetermined amounts Page 8 of 9

Retail Group, Inc. 20-33113 (KRH)

Thirty-First Omnibus Claims Objection

Schedule 1 - No Liability (Lease) Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 25 of 37
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

47 WPI - GRAND PLAZA SAN MARCOS, LLC

UAP - GRAND PLAZA, LLC

C/O NEWMARK MERRILL COMPANIES, INC.

ATTN: CATRINA BRANNON

427 COLLEGE BOULEVARD, SUITE K

OCEANSIDE, CA 92057

4/2/2021 20-33115 (KRH) Charming Shoppes, Inc. 6362 $ 6,813.01

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

48 WPI - GRAND PLAZA SAN MARCOS, LLC

UAP - GRAND PLAZA, LLC

C/O NEWMARK MERRILL COMPANIES, INC.

ATTN: CATRINA BRANNON

427 COLLEGE BOULEVARD, SUITE K

OCEANSIDE, CA 92057

4/2/2021 20-33144 (KRH) Lane Bryant #6243, Inc. 6359 $ 6,813.01

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

49 WPI - GRAND PLAZA SAN MARCOS, LLC

UAP - GRAND PLAZA, LLC

C/O NEWMARK MERRILL COMPANIES, INC.

ATTN: CATRINA BRANNON

427 COLLEGE BOULEVARD, SUITE K

OCEANSIDE, CA 92057

4/2/2021 20-33144 (KRH) Lane Bryant #6243, Inc. 6365 $ 6,813.01

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

50 WRIT 1140, LLC

C/O WASHREIT

1775 EYE STREET NW, SUITE 1000

WASHINGTON, DC 20006

3/24/2021 20-33113 (KRH) Ascena Retail Group, Inc. 6323 $ 41,256.81

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

TOTAL $ 1,136,594.59*

* Indicates claim contains unliquidated and/or undetermined amounts Page 9 of 9

Retail Group, Inc. 20-33113 (KRH)

Thirty-First Omnibus Claims Objection

Schedule 1 - No Liability (Lease) Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 26 of 37
253950457 v1 

Schedule 2 

Partially Satisfied Lease Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 27 of 37
ASSERTED CLAIMS MODIFIED CLAIMS

NAME CLAIM# DEBTOR PRIORITY 

STATUS

AMOUNT DEBTOR PRIORITY 

STATUS

AMOUNT

1 330 MADISON ASSOCIATES, LLC

C/O JONES LANG LASALLE 

AMERICAS, INC.

330 MADISON AVENUE

2ND FLOOR MANAGEMENT OFFICE

ATTENTION: GENERAL MANAGER

NEW YORK, NY 10017

6198 AnnTaylor Retail, Inc. Administrative $182,291.75

AnnTaylor Retail, Inc. Unsecured $2,331,257.18

Subtotal $2,513,548.93

AnnTaylor Retail, Inc. Administrative $0.00

AnnTaylor Retail, Inc. Unsecured $2,331,257.18

Subtotal $2,331,257.18

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

2 ASH TREE SQUARE, LLC

C/O MANCO ABBOTT

P.O BOX 9440

FRESNO, CA 93792-9440

3077 Lane Bryant, Inc. Administrative $460.68

Lane Bryant, Inc. Unsecured $224,227.10

Subtotal $224,687.78

Lane Bryant, Inc. Administrative $0.00

Lane Bryant, Inc. Unsecured $224,227.10

Subtotal $224,227.10

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

3 BELLEVUE SQUARE, LLC

NOLD MUCHINSKY PLLC

10500 NE 8TH STREET, SUITE 930

BELLEVUE, WA 98004

6236 AnnTaylor Retail, Inc. Administrative $783.00

AnnTaylor Retail, Inc. Unsecured $496,901.17

Subtotal $497,684.17

AnnTaylor Retail, Inc. Administrative $0.00

AnnTaylor Retail, Inc. Unsecured $496,901.17

Subtotal $496,901.17

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

4 BFW/HOWELL ASSOCIATES, LLC

570 DELAWARE AVE

BUFFALO, NY 14202

943 Tween Brands, Inc. Administrative $6,459.96

Tween Brands, Inc. Unsecured $143,984.69

Subtotal $150,444.65

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $143,984.69

Subtotal $143,984.69

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

5 CRAIG REALTY GROUP-TULARE, 

LLC

CRAIG REALTY GROUP; ATTN: T. 

SWAN

4100 MACARTHUR BLVD., STE. 100

NEWPORT BEACH, CA 92660

2557 Lane Bryant #6243, Inc. Administrative $71,512.96

Lane Bryant #6243, Inc. Unsecured $100,175.38

Subtotal $171,688.34

Lane Bryant #6243, Inc. Administrative $0.00

Lane Bryant #6243, Inc. Unsecured $100,175.38

Subtotal $100,175.38

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

6 CRAIG REALTY GROUP-TULARE, 

LLC

ATTN: T. SWAN

4100 MACARTHUR BLVD., STE. 100

NEWPORT BEACH, CA 92660

2730 Tween Brands, Inc. Administrative $67,057.07

Tween Brands, Inc. Unsecured $27,814.36

Subtotal $94,871.43

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $27,814.36

Subtotal $27,814.36

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

Page 1 of 5

Retail Group, Inc. 20-33113 (KRH) 

Thirty-First Omnibus Claims Objection

Schedule 2 - Partially Satisfied Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 28 of 37
ASSERTED CLAIMS MODIFIED CLAIMS

NAME CLAIM# DEBTOR PRIORITY 

STATUS

AMOUNT DEBTOR PRIORITY 

STATUS

AMOUNT

7 DULLES 28 RETAIL CENTRE GROUP 

L.L.C.

LERNER CORPORATION

2000 TOWER OAKS BLVD., 8TH 

FLOOR

ROCKVILLE, MD 20852

228 Tween Brands, Inc. Administrative $2,535.85

Tween Brands, Inc. Unsecured $81,517.82

Subtotal $84,053.67

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $81,517.82

Subtotal $81,517.82

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

8 DULLES TOWN CENTER MALL L.L.C.

LERNER CORPORATION

2000 TOWER OAKS BLVD., 8TH 

FLOOR

ROCKVILLE, MD 20852

REEP-RTL DTC VA LLC AS 

TRANSFEREE OF DULLES TOWN 

CENTER MALL L.L.C.

ATTN: ALAN RUBENSTEIN

DULLES TOWN CENTER

C/O REAL ESTATE

51 MADISON AVENUE, 9TH FL

NEW YORK, NY 10010-1603

747 Tween Brands, Inc. Administrative $7,406.83

Tween Brands, Inc. Unsecured $305,213.37

Subtotal $312,620.20

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $305,213.37

Subtotal $305,213.37

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

9 FORUM LONE STAR, L.P.

C/O JASPAN SCHLESINGER LLP

300 GARDEN CITY PLAZA, 5TH 

FLOOR

GARDEN CITY, NY 11530

5503 Tween Brands, Inc. Administrative $6,898.84

Tween Brands, Inc. Unsecured $40,463.16

Subtotal $47,362.00

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $40,463.16

Subtotal $40,463.16

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

10 HAMMOND SQUARE, L.L.C

ATTN: JUSTIN R. GLENN

ADAMS AND REESE LLP

701 POYDRAS STREET, SUITE 4500

NEW ORLEANS, LA 70139

3343 Tween Brands, Inc. Administrative $12,545.01

Tween Brands, Inc. Unsecured $20,863.83

Subtotal $33,408.84

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $20,863.83

Subtotal $20,863.83

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

Page 2 of 5

Retail Group, Inc. 20-33113 (KRH) 

Thirty-First Omnibus Claims Objection

Schedule 2 - Partially Satisfied Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 29 of 37
ASSERTED CLAIMS MODIFIED CLAIMS

NAME CLAIM# DEBTOR PRIORITY 

STATUS

AMOUNT DEBTOR PRIORITY 

STATUS

AMOUNT

11 HG GALLERIA, LLC

SIMON PROPERTY GROUP - 

BANKRUPTCY

225 WEST WASHINGTON STREET

INDIANAPOLIS, IN 46204

2156 Tween Brands, Inc. Administrative $31,276.40

Tween Brands, Inc. Unsecured $1,087,284.18

Subtotal $1,118,560.58

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $1,087,284.18

Subtotal $1,087,284.18

Reason: All administrative asserted liabilities for post-petition charges have been (1) paid through the date of the lease rejection for those leases ordered rejected or (2) no liability exists on the Debtor's 

books and records as the liability relates to executory contracts which were assumed and assigned to Premium Brands Opco LLC.

12 HIGHLAND COMMONS ASSOCIATES, 

LLC

570 DELAWARE AVE

BUFFALO, NY 14202

1317 Lane Bryant, Inc. Administrative $5,492.11

Lane Bryant, Inc. Unsecured $220,141.79

Subtotal $225,633.90

Lane Bryant, Inc. Administrative $0.00

Lane Bryant, Inc. Unsecured $220,141.79

Subtotal $220,141.79

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

13 KRE COLONIE OWNER LLC

BALLARD SPAHR LLP

ATTN: DUSTIN P. BRANCH

2029 CENTURY PARK EAST, SUITE 

1400

LOS ANGELES, CA 90067-2915

6240 Lane Bryant, Inc. Administrative $6,189.99

Lane Bryant, Inc. Unsecured $11,351.35

Subtotal $17,541.34

Lane Bryant, Inc. Administrative $0.00

Lane Bryant, Inc. Unsecured $11,351.35

Subtotal $11,351.35

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

14 L.I. PORTFOLIO HOLDINGS, LLC

DUSTIN P. BRANCH, ESQ.

BALLARD SPAHR LLP

2029 CENTURY PARK EAST, SUITE 

1400

LOS ANGELES, CA 90067-2915

6126 AnnTaylor Retail, Inc. Administrative $10,451.51

AnnTaylor Retail, Inc. Unsecured $381,170.61

Subtotal $391,622.12

AnnTaylor Retail, Inc. Administrative $0.00

AnnTaylor Retail, Inc. Unsecured $381,170.61

Subtotal $381,170.61

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

15 LINCOLN PLAZA CENTER, L.P.

SIMON PROPERTY GROUP - 

BANKRUPTCY

225 WEST WASHINGTON STREET

INDIANAPOLIS, IN 46204

2585 AnnTaylor Retail, Inc. Administrative $4,191.49

AnnTaylor Retail, Inc. Unsecured $125,163.86

Subtotal $129,355.35

AnnTaylor Retail, Inc. Administrative $0.00

AnnTaylor Retail, Inc. Unsecured $125,163.86

Subtotal $125,163.86

Reason: All administrative asserted liabilities for post-petition charges have been (1) paid through the date of the lease rejection for those leases ordered rejected or (2) no liability exists on the Debtor's 

books and records as the liability relates to executory contracts which were assumed and assigned to Premium Brands Opco LLC.

Page 3 of 5

Retail Group, Inc. 20-33113 (KRH) 

Thirty-First Omnibus Claims Objection

Schedule 2 - Partially Satisfied Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 30 of 37
ASSERTED CLAIMS MODIFIED CLAIMS

NAME CLAIM# DEBTOR PRIORITY 

STATUS

AMOUNT DEBTOR PRIORITY 

STATUS

AMOUNT

16 MALL AT MONTGOMERY, L.P.

SIMON PROPERTY GROUP - 

BANKRUPTCY

225 WEST WASHINGTON STREET

INDIANAPOLIS, IN 46204

2568 AnnTaylor Retail, Inc. Administrative $10,826.40

AnnTaylor Retail, Inc. Unsecured $379,504.11

Subtotal $390,330.51

AnnTaylor Retail, Inc. Administrative $0.00

AnnTaylor Retail, Inc. Unsecured $379,504.11

Subtotal $379,504.11

Reason: All administrative asserted liabilities for post-petition charges have been (1) paid through the date of the lease rejection for those leases ordered rejected or (2) no liability exists on the Debtor's 

books and records as the liability relates to executory contracts which were assumed and assigned to Premium Brands Opco LLC.

17 MEMORIAL CITY MALL, LP

C/O DUSTIN P. BRANCH, ESQ.

BALLARD SPAHR LLP

2029 CENTURY PARK EAST, SUITE 

1400

LOS ANGELES, CA 90067-2915

5519 Tween Brands, Inc. Administrative $3,577.44

Tween Brands, Inc. Unsecured $392,225.46

Subtotal $395,802.90

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $392,225.46

Subtotal $392,225.46

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

18 PIER PARK, LLC

SIMON PROPERTY GROUP

ATTN: BANKRUPTCY

225 WEST WASHINGTON STREET

INDIANAPOLIS, IN 46204

3310 Tween Brands, Inc. Administrative $1,743.89

Tween Brands, Inc. Unsecured $85,871.14

Subtotal $87,615.03

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $85,871.14

Subtotal $85,871.14

Reason: All administrative asserted liabilities for post-petition charges have been (1) paid through the date of the lease rejection for those leases ordered rejected or (2) no liability exists on the Debtor's 

books and records as the liability relates to executory contracts which were assumed and assigned to Premium Brands Opco LLC.

19 PREP HILLSIDE REAL ESTATE LLC

MEAGAN D. WEBB

DIRECTOR OF LEGAL SERVICES

5905 E. GALBRAITH RD.

SUITE 1000

CINCINNATI, OH 45236

5300 Tween Brands, Inc. Administrative $224.95

Tween Brands, Inc. Unsecured $108,014.14

Subtotal $108,239.09

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $108,014.14

Subtotal $108,014.14

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

20 TRAHWEN, LLC

570 DELAWARE AVE

BUFFALO, NY 14202

1365 Catherines, Inc. Administrative $10,226.84

Catherines, Inc. Unsecured $39,760.24

Subtotal $49,987.08

Catherines, Inc. Administrative $0.00

Catherines, Inc. Unsecured $39,760.24

Subtotal $39,760.24

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

Page 4 of 5

Retail Group, Inc. 20-33113 (KRH) 

Thirty-First Omnibus Claims Objection

Schedule 2 - Partially Satisfied Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 31 of 37
ASSERTED CLAIMS MODIFIED CLAIMS

NAME CLAIM# DEBTOR PRIORITY 

STATUS

AMOUNT DEBTOR PRIORITY 

STATUS

AMOUNT

21 TWC CHANDLER, LLC

BALLARD SPAHR LLP

DUSTIN P. BRANCH, ESQ.

2029 CENTURY PARK EAST, SUITE 

1400

LOS ANGELES, CA 90067-2915

5544 Tween Brands, Inc. Administrative $2,321.78

Tween Brands, Inc. Unsecured $517,201.92

Subtotal $519,523.70

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $517,201.92

Subtotal $517,201.92

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

22 WEINGARTEN NOSTAT, INC.

C/O WEINGARTEN REALTY 

INVESTORS

ATTN: LITIGATION DIVISION

2600 CITADEL PLAZA DR., SUITE 125

HOUSTON, TX 77008

4860 Lane Bryant, Inc. Administrative $427.06

Lane Bryant, Inc. Unsecured $199,035.58

Subtotal $199,462.64

Lane Bryant, Inc. Administrative $0.00

Lane Bryant, Inc. Unsecured $199,035.58

Subtotal $199,035.58

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

23 WG TAVERN SQUARE VENTURE LLC

C/O GROSS, ROMANICK, DEAN & 

DESIMONE, PC

3975 UNIVERSITY DRIVE, SUITE 410

FAIRFAX, VA 22030-2520

4436 AnnTaylor Retail, Inc. Administrative $8,703.33

AnnTaylor Retail, Inc. Unsecured $499,264.47

Subtotal $507,967.80

AnnTaylor Retail, Inc. Administrative $0.00

AnnTaylor Retail, Inc. Unsecured $499,264.47

Subtotal $499,264.47

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

24 YTC MALL OWNER, LLC

BALLARD SPAHR LLP

DUSTIN P. BRANCH, ESQ.

2029 CENTURY PARK EAST, SUITE 

1400

LOS ANGELES, CA 90067-2915

5484 Tween Brands, Inc. Administrative $1,967.00

Tween Brands, Inc. Unsecured $76,110.46

Subtotal $78,077.46

Tween Brands, Inc. Administrative $0.00

Tween Brands, Inc. Unsecured $76,110.46

Subtotal $76,110.46

Reason: All administrative asserted liabilities for post-petition lease charges have been paid through the date of the lease rejection.

TOTAL $ 8,350,089.51 TOTAL $ 7,894,517.37

Page 5 of 5

Retail Group, Inc. 20-33113 (KRH) 

Thirty-First Omnibus Claims Objection

Schedule 2 - Partially Satisfied Claims

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 32 of 37
253950457 v1 

Exhibit B 

Esposito Declaration

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

Document Page 33 of 37
253950457 v1 

1 

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)

)

DECLARATION OF ROB ESPOSITO 

IN SUPPORT OF THE PLAN ADMINISTRATOR’S 

THIRTY-FIRST OMNIBUS OBJECTION TO CLAIMS 

(NO LIABILITY LEASE CLAIMS AND 

PARTIALLY SATISFIED LEASE CLAIMS) 

I, Rob Esposito, hereby declare under penalty of perjury: 

1. I am a Senior Director at Alvarez & Marsal North America, LLC (together with 

employees of its affiliates, all of which are wholly-owned by its parent company and employees, 

its wholly owned subsidiaries, and independent contractors, “A&M”), a restructuring advisory 

services firm with numerous offices throughout the country and restructuring advisor to Jackson 

Square Advisors LLC, solely in its capacity as the Plan Administrator of the above-captioned 

reorganized debtors and debtors-in-possession (collectively, the “Debtors”). I submit this 

declaration (the “Declaration”) in support of the relief requested in The Plan Administrator’s

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 

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. 

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Document Page 34 of 37
253950457 v1 

2 

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

Lease Claims) (the “Objection”).2 

2. In my current position with A&M as an advisor to the Plan Administrator, I am 

generally familiar with the Debtors’ day-to-day operations, financing arrangements, business 

affairs, Schedules and Statements, and Books and Records. Such documents reflect, among 

other things, the Debtors’ liabilities and the amounts owed to their creditors as of the Petition 

Date. Except as otherwise stated herein, all facts set forth herein are based upon my personal 

knowledge of the Debtors’ operations and finances, information learned from my review of 

relevant documents, or information received from other members of the Debtors’ management, 

the Debtors’ and Plan Administrator’s advisors, including my team at A&M, or employees of 

the Debtors. I have read the Objection filed contemporaneously herewith and to the best of my 

knowledge, information, and belief, the assertions made in the Objection are accurate. If I were 

called upon to testify, I could and would testify competently to the facts set forth herein. I am 

authorized to submit this Declaration on behalf of the Plan Administrator. 

3. Considerable resources and time have been expended in reviewing and reconciling 

the Proofs of Claim filed or pending against the Debtors in these cases. 

4. The Plan Administrator has identified 50 No Liability Lease Claims listed on 

Schedule 1 to Exhibit A, in the aggregate claimed amount of $1,136,594.59. To the best of my 

knowledge, information, and belief, and insofar as I have been able to ascertain after reasonable 

inquiry, the No Liability Lease Claims do not accurately reflect amounts owed by the Debtors 

according to their Books and Records. The administrative liabilities asserted in the No Liability 

Lease Claims are (1) for postpetition lease charges that have been satisfied in the ordinary course 

2

 Capitalized terms used in this Declaration but not defined herein have the meanings given to such terms in the 

Objection. 

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253950457 v1 

3 

of the Debtors’ business through the applicable rejection date for each of the underlying leases; 

(2) are for postpetition lease charges pursuant to leases that have been assumed and assigned to 

Premium Brands Opco LLC; or (3) are made on account of leases with Maurices Incorporated, a 

non-Debtor entity. Failure to disallow and expunge the No Liability Lease Claims could result in 

the applicable claimants receiving undue recoveries against the Debtors’ estates, to the detriment 

of other similarly situated creditors. Moreover, elimination of the No Liability Lease Claims will 

enable the Plan Administrator to maintain a more accurate claims register. As such, I believe that 

disallowance and expungement of the No Liability Lease Claims on the terms set forth in the 

Objection and Schedule 1 annexed to Exhibit A is appropriate. 

5. The Plan Administrator has identified 24 Partially Satisfied Lease Claims listed on 

Schedule 2 to Exhibit A, in the aggregate claimed amount of $8,350,089.51. The Administrative 

Portion of the Partially Satisfied Lease Claims, to which the Plan Administrator objects, is in the 

aggregate claimed amount of $455,572.14. To the best of my knowledge, information, and belief, 

and insofar as I have been able to ascertain after reasonable inquiry, the Administrative Portion of 

each of the Partially Satisfied Lease Claims has been previously satisfied in these chapter 11 cases 

or relates to executory contracts that the Debtors assumed and assigned. Failure to modify the 

Partially Satisfied Lease Claims by disallowing and expunging each of their respective 

Administrative Portions could result in each relevant claimant receiving an unwarranted recovery 

against the Debtors’ estates, to the detriment of other similarly situated creditors. Moreover, 

disallowance of these claims will enable the claims register to reflect more accurately the Proofs 

of Claim asserted against the Debtors’ estates. As such, I believe that disallowance and 

expungement of the Administrative Portion of each of the Partially Satisfied Lease Claims as 

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

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253950457 v1 

4 

indicated by the amounts identified in the “Modified Claims” column on Schedule 2 annexed to 

Exhibit A and on the terms set forth in the Objection is appropriate. 

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: July 27, 2021 /s/ Rob Esposito

Rob Esposito

 Senior Director 

Alvarez & Marsal North America, LLC

Case 20-33113-KRH Doc 2333 Filed 07/27/21 Entered 07/27/21 19:03:07 Desc Main

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