KIRKLAND & ELLIS LLP 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 

KIRKLAND & ELLIS INTERNATIONAL LLP 

Edward O. Sassower, P.C. 

Steven N. Serajeddini, P.C. (admitted pro hac vice) 

601 Lexington Avenue

New York, New York 10022 

Telephone: (212) 446-4800 

Facsimile: (212) 446-4900 

-andJohn R. Luze (admitted pro hac vice) 

300 North LaSalle 

Chicago, Illinois 60654 

Telephone: (312) 862-2000 

Facsimile: (312) 862-2200 

Co-Counsel to the Debtors and Debtors in Possession

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) 

 ) 

 Debtors ) (Jointly Administered) 

 ) 

NOTICE OF THE DEBTORS’ 

FOURTEENTH OMNIBUS OBJECTION TO CLAIMS 

PLEASE TAKE NOTICE THAT on January 14, 2021, Retail Group, Inc. and its debtor 

affiliates (collectively, the “Debtors”)2 filed the Debtors’ Fourteenth Omnibus Objection to Claims 

[Docket No. 1477] (the “Omnibus Objection”) with the Court. A copy of the Omnibus Objection 

is attached to this notice (the “Objection Notice”) as Exhibit 1. By the Omnibus Objection, the 

Debtors are seeking to disallow, expunge, and modify claims, including your claim(s), as set forth 

on Exhibit A thereto. 

PLEASE TAKE FURTHER NOTICE THAT on December 23, 2020, 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. 1387] (the “Order”), by which the Court approved procedures for filing omnibus 

 

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

claims and noticing agent at http://cases.primeclerk.com/ascena. The location of Debtor Retail Group, Inc.’s 

principal place of business and the 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. 

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objections to proofs of claim (collectively, the “Claims” and each individually, a “Claim”) in 

connection with the above-captioned chapter 11 cases (the “Omnibus Objection Procedures”). 

YOU ARE RECEIVING THIS OBJECTION NOTICE BECAUSE ALL PROOFS OF 

CLAIM LISTED HEREIN THAT YOU FILED AGAINST ONE OR MORE OF THE DEBTORS 

IN THE ABOVE-CAPTIONED CHAPTER 11 CASES ARE SUBJECT TO THE OBJECTION. 

YOUR RIGHTS MAY BE AFFECTED BY THE OBJECTION. THEREFORE, YOU SHOULD 

READ THIS OBJECTION NOTICE (INCLUDING THE 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 AND SERVED ON THE OBJECTING PARTY WITHIN 21 CALENDAR 

DAYS OF THE MAILING OF THIS OBJECTION (THE “RESPONSE DEADLINE”), 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 disallowance and expungement of your 

Claim(s) listed above and if you are unable to resolve the Omnibus Objection with the Debtors 

before the deadline to object, then you must file and serve a written response (the “Response”) to 

the Omnibus Objection in accordance with this Objection Notice. 

If you do not oppose the disallowance and expungement of your Claim(s) listed above, 

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 

February 4, 2021 (the “Response Deadline”). 

THE 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 counsel for the Debtors: 

 Kirkland & Ellis LLP 

 Attn: John R. Luze and 

Jeffrey Michalik 

300 North LaSalle Street 

Chicago, Illinois 60654 

Email: 

john.luze@kirkland.com 

jeff.michalik@kirkland.com 

and 

Cooley LLP

Attn: Cullen D. Speckhart and 

Olya Antle 

1299 Pennsylvania Ave., NW, Ste 700 

 Washington, DC 20004-2400 

Email: 

 cspeckhart@cooley.com 

 oantle@cooley.com 

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Unless otherwise adjourned by the Court or the Debtors pursuant to the Omnibus Objection 

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

1:00 p.m. prevailing Eastern Time on March 18, 2021, before the Honorable Kevin R. 

Huennekens, in the United States Bankruptcy Court for the Eastern District of Virginia, located at 

701 East Broad Street, Suite 5100, Richmond, VA 23219-1888. You may register for the hearing

through the following hyperlink: 

https://www.zoomgov.com/meeting/register/vJItdOuvqT4vHiBl_8x3gu_UfEQyMnj_rtE 

Parties who wish to attend the hearing but do not intend on participating in the hearing 

(listen-only), are not required to register in advance and may attend the hearing by using the 

following dial-in numbers: 

Phone Number: 1-866-590-5055 

Access Code: 4377075 

Security Code: 31821 

Phone Number: 1-888-363-4734 

Access Code: 3238664 

Security Code: 31821 

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): 

A. a caption setting forth the name of the Court, the name of the Debtors, the 

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

is directed; 

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

C. a concise statement setting forth the reasons why the 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; 

D. 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 

E. the claimant’s name, address, telephone number, and email address 

and/or the name, address, telephone number and email address of the 

claimant’s attorney and/or designated representative to whom the attorneys 

for the Debtors 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 the claimant’s 

Claims listed in the Omnibus Objection (including all Claims to be 

disallowed and expunged and the surviving Claims) and only for those 

Claims in the Omnibus Objection. 

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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 Objection Notice and timely 

serve it on the Debtors’ attorneys, the Debtors will present to the 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. The Debtors, however, reserve the right 

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

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

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

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 Court will be deemed a separate order with respect to 

such Claim. 

Additional Information 

Reply of the Debtors. The Debtors may file a reply to your Response or reply in oral 

argument at the hearing. In such event, the Debtors are permitted to file their reply no later than 

one calendar day before the hearing on the Omnibus Objection and the Response. 

Additional Discovery. Upon receipt of your Response, the Debtors may determine that 

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

In such event, the Debtors 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 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 (877) 930-4319. You may also obtain a copy of the Omnibus 

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

https://cases.primeclerk.com/ascena/. 

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

constitutes a waiver of the Debtors’ right to assert any claims, counterclaims, rights of offset or 

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

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claimant of the Debtors. Unless the Court allows your Claims or specifically orders otherwise, the 

Debtors have 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 Debtors) at a later date. In such 

event, you will receive a separate notice of any such objections. 

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Dated: January 14, 2021 

 

/s/ Cullen D. Speckhart

KIRKLAND & ELLIS LLP 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 

KIRKLAND & ELLIS INTERNATIONAL LLP

Edward O. Sassower, P.C. 

Steven N. Serajeddini, P.C. (admitted pro hac vice) 

601 Lexington Avenue 

New York, New York 10022 

Telephone: (212) 446-4800 

Facsimile: (212) 446-4900 

Email: edward.sassower@kirkland.com 

 steven.serajeddini@kirkland.com 

-andJohn R. Luze (admitted pro hac vice) 

300 North LaSalle Street 

Chicago, Illinois 60654 

Telephone: (312) 862-2000 

Facsimile: (312) 862-2200 

Email: john.luze@kirkland.com 

 

Co-Counsel to the Debtors and Debtors in Possession

 

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