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)

)

NOTICE OF FILING OF REVISED PROPOSED ORDER SUSTAINING THE PLAN 

ADMINISTRATOR’S THIRTIETH OMNIBUS OBJECTION TO CLAIMS 

PLEASE TAKE NOTICE that on July 27, 2021, Jackson Square Advisors LLC, in its 

capacity as the plan administrator (the “Plan Administrator”) of the above-captioned debtors and 

debtors in possession (collectively, the “Debtors,” and after the effective date of the chapter 11 plan 

confirmed in these cases, the “Reorganized Debtors”) filed The Plan Administrator’s Thirtieth 

Omnibus Objection to Claims (No Liability Claims and Substantive Duplicate Claims) (the 

“Objection”) [Docket No. 2332], which includes a proposed form of order (the “Proposed Order”). 

 PLEASE TAKE FURTHER NOTICE that the Plan Administrator is hereby filing a 

revised proposed Order Sustaining The Plan Administrator’s Thirtieth Omnibus Objection to 

Claims (the “Revised Proposed Order”), which is attached hereto as Exhibit A. 

 PLEASE TAKE FURTHER NOTICE that attached hereto as Exhibit B is a redline of 

the Revised Proposed Order as compared to the Proposed Order. 

 PLEASE TAKE FURTHER NOTICE that copies of the Objection, the Revised 

Proposed Order, and all other documents filed in these chapter 11 cases are available free of charge 

by: (a) visiting the Reorganized Debtors’ restructuring website at 

https://cases.primeclerk.com/ascena and/or (b) by calling (877) 930-4319 (toll free) or, for 

international callers, or (347) 817-4076 (international). You may also obtain copies of any 

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 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

Document Page 1 of 33
pleadings filed in these chapter 11 cases for a fee via PACER at: http://www.vaeb.uscourts.gov in 

accordance with the procedures and fees set forth therein. 

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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EXHIBIT A 

Revised Proposed Order 

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253913863 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)

)

ORDER SUSTAINING THE PLAN ADMINISTRATOR’S THIRTIETH 

OMNIBUS OBJECTION TO 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 (collectively, the “Debtors”), 

for entry of an order (this “Order”), modifying, disallowing and expunging the Proofs of Claim set 

forth on Schedules 1–3 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 this Court may enter a final order 

consistent with Article III of the United States Constitution; and this Court having found that venue 

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. 2332]. 

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2 

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 Claims set forth on the attached Schedule 1 are hereby disallowed 

and expunged in their entirety. 

3. The Substantive Duplicate Claims identified in the column titled “Claims to be 

Disallowed” on the attached Schedule 2 are hereby disallowed and expunged in their entirety; 

provided that this Order will not affect the Proofs of Claim identified on Schedule 2 attached 

hereto in the column titled “Remaining Claims.” 

4. The Incorrect Priority Claim set forth on the attached Schedule 3 is hereby 

modified as to the priority status as identified in the column titled “Modified Claims” in Schedule 

3 to this Order. All parties’ rights are reserved with respect to the Modified Claims, including the 

GUC Trust’s right to object to the unsecured amounts identified on Schedule 3. 

5. 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 

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3 

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

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

other contested matters covered hereby. 

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

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

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

accordance with entry of the relief granted in this Order. 

8. 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. 

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

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4 

relief granted in this Order in accordance with the Objection. 

10. 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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253913863 v1 

5 

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 

Case 20-33113-KRH Doc 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

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253913863 v1 

Schedule 1 

No Liability Claims

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NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

1 ASSOCIATED MATERIAL HANDLING INDUSTRIES, INC. DBA ASSOCIATED 

INTEGRATED SUPPLY CHAIN SOLUTIONS

133 NORTH SWIFT ROAD

ADDISON, IL 60101

1/17/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5525 $ 8,061.20

Reason: The invoices asserted in the proof of claim have been paid by ACH numbers 1130487, 1130753, 1130828 and 1130911 dated 01/12/2021, 02/03/2021, 02/08/2021 and 02/15/2021, respectively.

2 BOOKER, ARNETTE U

WANTED ENTERPRISE

118 OLYMPIC AVENUE

BUFFALO, NY 14215

1/12/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5172 $ 0.00

Reason: No liability exists on the Debtor's books and records on account of wages. The former employee was paid through her termination date of 11/16/2019. 

3 CHANGSHU EVERBEST IMP & EXP CO.,LTD

RM:904-911, 4TH BUILDING, JIAHE PLAZA

HUANGHE ROAD

CHANGSHU CITY, JIANGSU PROVINCE, 215500

CHINA

9/24/2020 20-33134 (KRH) AnnTaylor, Inc. 2418 $ 567.85

Reason: No liability exists on the Debtor's books and records on account of this claim.

4 CONSOLIDATED FIRE PROTECTION, INC

153 TECHNOLOGY DRIVE, SUITE 200

IRVINE, CA 92618-9261

1/15/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5431 $ 10,992.87

Reason: Various invoice liability totaling $1,583.78 does not exist in the Debtors' books and records.

Invoice numbers 101328897, 101328898, 101332058, 101332086, 101332927, 101334728, 101334730, 101334866, 101335421, 101335952, 101336141, 101336841, 101338473, 101341693, 

101341694, 101341695, 101341697, 101342066, 101342067, 101342068,

101342071 in the aggregate amount of $2,359.91 represent liability of the non-debtor entity Maurice's, Inc.

Invoice numbers 101296347, 101296354, 101326405, 101329455, 101329900, 101330511, 101330646, 101334872, 101339243, 101340948, 101341168, 101341698, 101342069, 101342070, 

101342072, 101342214 in the aggregate amount of $7,049.18 were paid via ACH via payment numbers 7797081 (dated 1/19/2021), 7797640 (dated 3/1/2021), 7797878 (dated 3/8/2021), 7797946 

(dated 3/15/2021), 2000008009 (dated 1/9/2021, 1/14/2021 and 1/15/2021), 2000009125 (dated 2/20/2021), 2000009223 (dated 2/27/2021 and 10/26/2021), 2000009569 (dated 2/28/2021) and 

2000010503 (dated 3/18/2021).

5 CONVERSANT, LLC

C/O TABITHA THOMANN, SENIOR COUNSEL

6021 CONNECTION DRIVE

IRVING, TX 75039

1/19/2021 20-33134 (KRH) AnnTaylor, Inc. 5470 $ 107,424.30

Reason: Invoice numbers 1279764378, ECU0000003611, 1279764370 totaling $76,999.30 were paid via ACH with payment numbers 2000009086 (dated 1/16/2021), 2000092769 (dated 6/14/2021) 

and 2000012208 (dated 1/16/2021).

Various invoice liability totaling $30,425.00 does not exist in the Debtors' books and records.

Page 1 of 4

Retail Group, Inc. 20-33113 (KRH)

Thirtieth Omnibus Claims Objection

Schedule 1 - No Liability Claims

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Document Page 10 of 33
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

6 COOK, DRUCILLIA

624 PLACER LN

SUISUN CITY, CA 94585

8/20/2020 20-33113 (KRH) Ascena Retail Group, Inc. 795 $ 268.00

Reason: No liability exists on the Debtor's books and records on account of wages. Pursuant to the Asset Purchase Agreement by and among Ascena Retail Group, Inc. (Seller) and Premium Apparel 

LLC (Purchaser), the Purchaser assumed all liabilities of the Seller regarding the frozen pension plan.

7 CRITEO CORP

387 PARK AVENUE SOUTH

11TH AND 12TH FLOOR

NEW YORK, NY 10016

1/19/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5826 $ 121,482.32

Reason: No liability exists on the Debtor's books and records on account of invoice number 13US20114420.

8 FULIDA GROUP HANGZHOU IMPORT AND EXPORT CO., LTD.

ADDRESS: NO.2 FARM, EAST

XINWAN, XIAOSHAN, HANGZHOU

ZHEJIANG

, 311228

CHINA

9/28/2020 20-33134 (KRH) AnnTaylor, Inc. 2937 $ 1,193.60

Reason: No liability exists on the Debtor's books and records on account of this claim.

9 HANGZHOU FUEN TEXTILE CO., LTD.

ADD: JINGJIANG INDUSTRIAL PARK

XIAOSHAN DISTRICT

HANGZHOU CITY, 311223

CHINA

11/19/2020 20-33134 (KRH) AnnTaylor, Inc. 4722 $ 16,234.48

Reason: No liability exists on the Debtors' books and records on account of invoice number FN17412G1 in the amount of $8,117.24.

10 HOPE STAR OVERSEAS LIMITED

ADD:FLOOR 5 BAIJIAQIAO

INDUSTRIAL PARK, ZHANGQING RD.

ZHANGJIAGANG, JIANGSU, 215600

CHINA

10/10/2020 20-33134 (KRH) AnnTaylor, Inc. 4380 $ 11,118.28

Reason: No liability exists on the Debtors' books and records. The Debtors have no record of the invoices asserted in the Proof of Claim.

11 MYERS, CHAKARA

MYERS ANDREW

25620 NORTHLINE RD

TAYLOR, MI 48180-4585

4/6/2021 20-33113 (KRH) Ascena Retail Group, Inc. 6372 $ 1,040.00

Reason: No liability exists on the Debtor's books and records on account of wages. The former employee was paid all wages due through the termination date of 2/25/2020.

Page 2 of 4

Retail Group, Inc. 20-33113 (KRH)

Thirtieth Omnibus Claims Objection

Schedule 1 - No Liability Claims

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Document Page 11 of 33
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

12 PRUDENTIAL SECURITY, INC.

20600 EUREKA RD., STE. 900

TAYLOR, MI 48180

1/12/2021 20-33136 (KRH) Ascena Retail Holdings, Inc. 5178 $ 2,313.36

Reason: Invoice number 4432012, in the amount of $2,313.36, was paid by ACH via payment number 1130551 dated 1/12/2021.

13 RETRIEVEX, INC.

ACCESS INFORMATION MANAGEMENT

ATTN: MARGARET APPLIN

500 UNICORN PARK DRIVE

SUITE 503

WOBURN, MA 01801

9/29/2020 20-33113 (KRH) Ascena Retail Group, Inc. 3093 $ 24,755.28

Reason: No liability exists on the Debtors' books and records. The contract associated with this claim was assumed by the Debtors.

14 ROSS, ERIKA

22773 ANOKA ROAD

APPLE VALLEY, CA 92308

10/4/2020 20-33113 (KRH) Ascena Retail Group, Inc. 4284 $ 103.25

Reason: No liability exists on the Debtors' books and records. The Claimant asserts liability which was satisfied as part of a Joint Stipulation of Class Action Settlement and Release which was approved 

by the Superior Court of the State of California (County of San Diego). Subsequently, the Debtors' paid the settlement amount as provided in the Settlement & Release.

15 SEVENTH & OAK (ANNABEL OKEYA)

3120 RUTHERFORD ROAD, SUITE 351

VAUGHAN, ON L4K 0B2

CANADA

9/16/2020 20-33113 (KRH) Ascena Retail Group, Inc. 1603 $ 216.00

Reason: Post-petition invoice number 106, in the amount of $216, was paid on 6/23/2021 via payment number 200017583.

16 SHAOXING GREENISLAND TEXTILE CO.,LTD

ROOM 2201,CENTRAL BLDG

KEQIAO

SHAOXING, 312030

CHINA

9/16/2020 20-33122 (KRH) Ann, Inc. 1597 $ 781.78

Reason: No liability exists on the Debtor's books and records on account of this claim.

17 SHENZHEN BOYANGTEX CO.,LTD.

RM#11B,JINFENG BUILDING

SHANGBU NAN ROAD

FUTIAN DISTRICT

SHENZHEN, GUANGDONG, 518031

CHINA

9/24/2020 20-33134 (KRH) AnnTaylor, Inc. 2459 $ 1,287.02

Reason: No liability exists on the Debtors' books and records. The Debtor's have no record of the invoices or receipt of the samples described in this claim.

Page 3 of 4

Retail Group, Inc. 20-33113 (KRH)

Thirtieth Omnibus Claims Objection

Schedule 1 - No Liability Claims

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Document Page 12 of 33
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

18 SOGOSURVEY LLC

2291 WOOD OAK DRIVE, #300

HERNDON, VA 20171

9/1/2020 20-33170 (KRH) Tween Brands, Inc. 1094 $ 2,529.00

Reason: No liability exists on the Debtor's books and records. Invoice 1371 for $2,529.00 was paid via check #50058616 dated 11/10/2020.

19 STORED VALUE SOLUTIONS, A DIVISION OF COMDATA INC.

5301 MARYLAND WAY, SUITE 100

BRENTWOOD, TN 37027

1/15/2021 20-33112 (KRH) DBCM Holdings, LLC 5403 $ 65,620.84

Reason: No liability exists on the Debtor's books and records on account of this claim.

20 STORED VALUE SOLUTIONS, A DIVISION OF COMDATA INC.

5301 MARYLAND WAY, SUITE 100

NASHVILLE, TN 37027

1/15/2021 20-33161 (KRH) Too GC, LLC 5409 $ 65,620.84

Reason: No liability exists on the Debtor's books and records on account of this claim.

21 SUZHOU D&C MANUFACTURE GROUP

14F,ZHONGXIANG FINANCIAL BUILDING,

NO.1060 JIAYUAN ROAD

XIANGCHENG DISTRICT, SUZHOU, 215131

CHINA

9/25/2020 20-33134 (KRH) AnnTaylor, Inc. 2637 $ 441.35

Reason: No liability exists on the Debtor's books and records on account of this claim.

22 WINBOND (HONG KONG) CO., LIMITED

ADD: 2ND FLOOR BUILDING H, LINGNAN CREATIVE PARK

NO. 583 XINJIAO CENTRAL ROAD, HAIZHU DISTRICT

GUANGZHOU, GUANGDONG PROVINCE, 510220

CHINA

8/31/2020 20-33134 (KRH) AnnTaylor, Inc. 1129 $ 2,543.00

Reason: No liability exists on the Debtors' books and records. The Debtor's have no record of the invoices or vendor described in this claim.

23 WOLF, NINA

2609 OAK GROVE STREET

BAKERSFIELD, CA 93311

1/14/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5319 $ 308.00

Reason: No liability exists on the Debtors' books and records. The Claimant asserts liability which was satisfied as part of a Joint Stipulation of Class Action Settlement and Release which was approved 

by the Superior Court of the State of California (County of San Diego). Subsequently, the Debtors' paid the settlement amount as provided in the Settlement & Release.

24 YANGZHOU DONGSHENG WOOL CO LTD

NO.12 MUYANG ROAD

YANGZHOU, 

CHINA

9/23/2020 20-33134 (KRH) AnnTaylor, Inc. 2153 $ 1,714.50

Reason: No liability exists on the Debtor's books and records on account of this claim.

TOTAL $ 446,617.12

Page 4 of 4

Retail Group, Inc. 20-33113 (KRH)

Thirtieth Omnibus Claims Objection

Schedule 1 - No Liability Claims

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253913863 v1 

Schedule 2 

Substantive Duplicate Claims 

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CLAIMS TO BE DISALLOWED REMAINING CLAIMS

NAME

DATE 

FILED

CASE NUMBER / 

DEBTOR CLAIM # CLAIM AMOUNT NAME

DATE 

FILED

CASE NUMBER / 

DEBTOR CLAIM # CLAIM AMOUNT

1 SILVEIRA, ISABELLA

222 STROME STREET

NEW ALBANY, OH 43054

01/16/21 Catherines, Inc.

20-33158 (KRH)

5499 $ 2,400.00 SILVEIRA, ISABELLA

222 STROME STREET

NEW ALBANY, OH 43054

08/06/20 Ascena Retail Group, Inc.

20-33113 (KRH)

406 $ 5,700.00

Reason: Claimant asserts administrative classification for pre-petition liability which duplicates the general unsecured liability for two invoices (031320 and 021420) asserted in the Remaining Claim.

2 SOPHIA VOURDOUKIS 

INC

345 DENNIS STREET

OCEANSIDE, NY 11572-

4313

01/15/21 Ascena Retail Group, Inc.

20-33113 (KRH)

5420 $ 4,950.00 VOURDOUKIS, SOPHIA

345 DENNIS STREET

OCEANSIDE, NY 11572

08/19/20 AnnTaylor Retail, Inc.

20-33132 (KRH)

303 $ 9,900.00

Reason: Claimant asserts administrative classification for pre-petition liability which duplicates the general unsecured liability asserted in the Remaining Claim.

Total $ 7,350.00 Total $ 15,600.00

Page 1 of 1

Retail Group, Inc. 20-33113 (KRH) 

Thirtieth Omnibus Claims Objection

Schedule 2 - Substantive Duplicate Claims

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253913863 v1 

Schedule 3 

Incorrect Priority Claim 

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Document Page 16 of 33
ASSERTED CLAIMS MODIFIED CLAIMS

NAME CLAIM# DEBTOR PRIORITY 

STATUS

AMOUNT DEBTOR PRIORITY 

STATUS

AMOUNT

1 KINDRED SYSTEMS INC.

169 STILLMAN STREET

SAN FRANCISCO, CA 94107

903 Ascena Retail Group, Inc. 503(b)(9) $21,600.00 Ascena Retail Group, Inc. 503(b)(9) $0.00

Ascena Retail Group, Inc. Unsecured $21,600.00

Subtotal $21,600.00

Reason: The invoices asserted in the proof of claim are for pre-petition services which should be reclassified to general unsecured.

TOTAL $ 21,600.00 TOTAL $ 21,600.00

Page 1 of 1

Retail Group, Inc. 20-33113 (KRH) 

Thirtieth Omnibus Claims Objection

Schedule 3 - Incorrect Priority Claim

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Document Page 17 of 33
EXHIBIT B 

Redline 

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253913863 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)

)

ORDER SUSTAINING THE PLAN ADMINISTRATOR’S THIRTIETH 

OMNIBUS OBJECTION TO CLAIMS 

(NO LIABILITY CLAIMS AND 

SUBSTANTIVE DUPLICATE 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”), modifying, disallowing and 

expunging the portion of each ProofProofs of Claim set forth on Schedules 1–23 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 

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. ____].2332].

Formatted: Border: Bottom: (Single solid line, Auto, 0.5 pt

Line width)

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Document Page 19 of 33
2

August 15, 1984; and that 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 Claims set forth on the attached Schedule 1 are hereby disallowed 

and expunged in their entirety. 

3. The Substantive Duplicate Claims identified in the column titled “Claims to be 

Disallowed” on the attached Schedule 2 are hereby disallowed and expunged in their entirety; 

provided that this Order will not affect the Proofs of Claim identified on Schedule 2 attached 

hereto in the column titled “Remaining Claims.” 

4. The Incorrect Priority Claim set forth on the attached Schedule 3 is hereby 

modified as to the priority status as identified in the column titled “Modified Claims” in Schedule 

3 to this Order. All parties’ rights are reserved with respect to the Modified Claims, including the 

GUC Trust’s right to object to the unsecured amounts identified on Schedule 3. 

4.5. 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 

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3

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 

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

other contested matters covered hereby. 

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

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

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

accordance with entry of the relief granted in this Order. 

7.8. 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. 

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4

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

relief granted in this Order in accordance with the Objection. 

9.10. 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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253913863 v1 

5 

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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253913863 v1 

Schedule 1 

No Liability Claims

Case 20-33113-KRH Doc 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

Document Page 24 of 33
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

1 ASSOCIATED MATERIAL HANDLING INDUSTRIES, INC. DBA ASSOCIATED 

INTEGRATED SUPPLY CHAIN SOLUTIONS

133 NORTH SWIFT ROAD

ADDISON, IL 60101

1/17/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5525 $ 8,061.20

Reason: The invoices asserted in the proof of claim have been paid by ACH numbers 1130487, 1130753, 1130828 and 1130911 dated 01/12/2021, 02/03/2021, 02/08/2021 and 02/15/2021, respectively.

2 BOOKER, ARNETTE U

WANTED ENTERPRISE

118 OLYMPIC AVENUE

BUFFALO, NY 14215

1/12/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5172^ $ 1,700.00

Reason: No liability exists on the Debtor's books and records on account of wages. The former employee was paid through her termination date of 11/16/2019. 

^Claim also filed on the Schedule 1 to the Twenty-Eighth Omnibus Claims Objection for Late-Filed Claims

3 CHANGSHU EVERBEST IMP & EXP CO.,LTD

RM:904-911, 4TH BUILDING, JIAHE PLAZA

HUANGHE ROAD

CHANGSHU CITY, JIANGSU PROVINCE, 215500

CHINA

9/24/2020 20-33134 (KRH) AnnTaylor, Inc. 2418 $ 567.85

Reason: No liability exists on the Debtor's books and records on account of this claim.

4 CONSOLIDATED FIRE PROTECTION, INC

153 TECHNOLOGY DRIVE, SUITE 200

IRVINE, CA 92618-9261

1/15/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5431 $ 10,992.87

Reason: Various invoice liability totaling $1,583.78 does not exist in the Debtors' books and records.

Invoice numbers 101328897, 101328898, 101332058, 101332086, 101332927, 101334728, 101334730, 101334866, 101335421, 101335952, 101336141, 101336841, 101338473, 101341693, 

101341694, 101341695, 101341697, 101342066, 101342067, 101342068,

101342071 in the aggregate amount of $2,359.91 represent liability of the non-debtor entity Maurice's, Inc.

Invoice numbers 101296347, 101296354, 101326405, 101329455, 101329900, 101330511, 101330646, 101334872, 101339243, 101340948, 101341168, 101341698, 101342069, 101342070, 

101342072, 101342214 in the aggregate amount of $7,049.18 were paid via ACH via payment numbers 7797081 (dated 1/19/2021), 7797640 (dated 3/1/2021), 7797878 (dated 3/8/2021), 7797946

(dated 3/15/2021), 2000008009 (dated 1/9/2021, 1/14/2021 and 1/15/2021), 2000009125 (dated 2/20/2021), 2000009223 (dated 2/27/2021 and 10/26/2021), 2000009569 (dated 2/28/2021) and 

2000010503 (dated 3/18/2021).

Page 1 of 5

Retail Group, Inc. 20-33113 (KRH)

Thirtieth Omnibus Claims Objection

Schedule 1 - No Liability Claims

Case 20-33113-KRH Doc 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

Document Page 25 of 33
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

5 CONVERSANT, LLC

C/O TABITHA THOMANN, SENIOR COUNSEL

6021 CONNECTION DRIVE

IRVING, TX 75039

1/19/2021 20-33134 (KRH) AnnTaylor, Inc. 5470 $ 107,424.30

Reason: Invoice numbers 1279764378, ECU0000003611, 1279764370 totaling $76,999.30 were paid via ACH with payment numbers 2000009086 (dated 1/16/2021), 2000092769 (dated 6/14/2021) 

and 2000012208 (dated 1/16/2021).

Various invoice liability totaling $30,425.00 does not exist in the Debtors' books and records.

6 COOK, DRUCILLIA

624 PLACER LN

SUISUN CITY, CA 94585

8/20/2020 20-33113 (KRH) Ascena Retail Group, Inc. 795 $ 268.00

Reason: No liability exists on the Debtor's books and records on account of wages. Pursuant to the Asset Purchase Agreement by and among Ascena Retail Group, Inc. (Seller) and Premium Apparel 

LLC (Purchaser), the Purchaser assumed all liabilities of the Seller regarding the frozen pension plan.

7 CRITEO CORP

387 PARK AVENUE SOUTH

11TH AND 12TH FLOOR

NEW YORK, NY 10016

1/19/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5826 $ 121,482.32

Reason: No liability exists on the Debtor's books and records on account of invoice number 13US20114420.

8 FULIDA GROUP HANGZHOU IMPORT AND EXPORT CO., LTD.

ADDRESS: NO.2 FARM, EAST

XINWAN, XIAOSHAN, HANGZHOU

ZHEJIANG

, 311228

CHINA

9/28/2020 20-33134 (KRH) AnnTaylor, Inc. 2937 $ 1,193.60

Reason: No liability exists on the Debtor's books and records on account of this claim.

9 HANGZHOU FUEN TEXTILE CO., LTD.

ADD: JINGJIANG INDUSTRIAL PARK

XIAOSHAN DISTRICT

HANGZHOU CITY, 311223

CHINA

11/19/2020 20-33134 (KRH) AnnTaylor, Inc. 4722 $ 16,234.48

Reason: No liability exists on the Debtors' books and records on account of invoice number FN17412G1 in the amount of $8,117.24.

10 HOPE STAR OVERSEAS LIMITED

ADD:FLOOR 5 BAIJIAQIAO

INDUSTRIAL PARK, ZHANGQING RD.

ZHANGJIAGANG, JIANGSU, 215600

CHINA

10/10/2020 20-33134 (KRH) AnnTaylor, Inc. 4380 $ 11,118.28

Reason: No liability exists on the Debtors' books and records. The Debtors have no record of the invoices asserted in the Proof of Claim.

Page 2 of 5

Retail Group, Inc. 20-33113 (KRH)

Thirtieth Omnibus Claims Objection

Schedule 1 - No Liability Claims

Case 20-33113-KRH Doc 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

Document Page 26 of 33
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

11 KINDRED SYSTEMS INC.

169 STILLMAN STREET

SAN FRANCISCO, CA 94107

8/24/2020 20-33113 (KRH) Ascena Retail Group, Inc. 903 $ 21,600.00

Reason: No liability exists on the Debtors' books and records. The Debtor has no record of the Claimant as a vendor nor does it have any record of the invoices asserted by the Claimant.

12 MYERS, CHAKARA

MYERS ANDREW

25620 NORTHLINE RD

TAYLOR, MI 48180-4585

4/6/2021 20-33113 (KRH) Ascena Retail Group, Inc. 6372 $ 1,040.00

Reason: No liability exists on the Debtor's books and records on account of wages. The former employee was paid all wages due through the termination date of 2/25/2020.

13 PRUDENTIAL SECURITY, INC.

20600 EUREKA RD., STE. 900

TAYLOR, MI 48180

1/12/2021 20-33136 (KRH) Ascena Retail Holdings, Inc. 5178 $ 2,313.36

Reason: Invoice number 4432012, in the amount of $2,313.36, was paid by ACH via payment number 1130551 dated 1/12/2021.

14 RETRIEVEX, INC.

ACCESS INFORMATION MANAGEMENT

ATTN: MARGARET APPLIN

500 UNICORN PARK DRIVE

SUITE 503

WOBURN, MA 01801

9/29/2020 20-33113 (KRH) Ascena Retail Group, Inc. 3093 $ 24,755.28

Reason: No liability exists on the Debtors' books and records. The contract associated with this claim was assumed by the Debtors.

15 ROSS, ERIKA

22773 ANOKA ROAD

APPLE VALLEY, CA 92308

10/4/2020 20-33113 (KRH) Ascena Retail Group, Inc. 4284 $ 103.25

Reason: No liability exists on the Debtors' books and records. The Claimant asserts liability which was satisfied as part of a Joint Stipulation of Class Action Settlement and Release which was approved 

by the Superior Court of the State of California (County of San Diego). Subsequently, the Debtors' paid the settlement amount as provided in the Settlement & Release.

16 SEVENTH & OAK (ANNABEL OKEYA)

3120 RUTHERFORD ROAD, SUITE 351

VAUGHAN, ON L4K 0B2

CANADA

9/16/2020 20-33113 (KRH) Ascena Retail Group, Inc. 1603 $ 216.00

Reason: Post-petition invoice number 106, in the amount of $216, was paid on 6/23/2021 via payment number 200017583.

17 SHAOXING GREENISLAND TEXTILE CO.,LTD

ROOM 2201,CENTRAL BLDG

KEQIAO

SHAOXING, 312030

CHINA

9/16/2020 20-33122 (KRH) Ann, Inc. 1597 $ 781.78

Reason: No liability exists on the Debtor's books and records on account of this claim.

Page 3 of 5

Retail Group, Inc. 20-33113 (KRH)

Thirtieth Omnibus Claims Objection

Schedule 1 - No Liability Claims

Case 20-33113-KRH Doc 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

Document Page 27 of 33
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

18 SHENZHEN BOYANGTEX CO.,LTD.

RM#11B,JINFENG BUILDING

SHANGBU NAN ROAD

FUTIAN DISTRICT

SHENZHEN, GUANGDONG, 518031

CHINA

9/24/2020 20-33134 (KRH) AnnTaylor, Inc. 2459 $ 1,287.02

Reason: No liability exists on the Debtors' books and records. The Debtor's have no record of the invoices or receipt of the samples described in this claim.

19 SOGOSURVEY LLC

2291 WOOD OAK DRIVE, #300

HERNDON, VA 20171

9/1/2020 20-33170 (KRH) Tween Brands, Inc. 1094 $ 2,529.00

Reason: No liability exists on the Debtor's books and records. Invoice 1371 for $2,529.00 was paid via check #50058616 dated 11/10/2020.

20 STORED VALUE SOLUTIONS, A DIVISION OF COMDATA INC.

5301 MARYLAND WAY, SUITE 100

BRENTWOOD, TN 37027

1/15/2021 20-33112 (KRH) DBCM Holdings, LLC 5403 $ 65,620.84

Reason: No liability exists on the Debtor's books and records on account of this claim.

21 STORED VALUE SOLUTIONS, A DIVISION OF COMDATA INC.

5301 MARYLAND WAY, SUITE 100

NASHVILLE, TN 37027

1/15/2021 20-33161 (KRH) Too GC, LLC 5409 $ 65,620.84

Reason: No liability exists on the Debtor's books and records on account of this claim.

22 SUZHOU D&C MANUFACTURE GROUP

14F,ZHONGXIANG FINANCIAL BUILDING,

NO.1060 JIAYUAN ROAD

XIANGCHENG DISTRICT, SUZHOU, 215131

CHINA

9/25/2020 20-33134 (KRH) AnnTaylor, Inc. 2637 $ 441.35

Reason: No liability exists on the Debtor's books and records on account of this claim.

23 WINBOND (HONG KONG) CO., LIMITED

ADD: 2ND FLOOR BUILDING H, LINGNAN CREATIVE PARK

NO. 583 XINJIAO CENTRAL ROAD, HAIZHU DISTRICT

GUANGZHOU, GUANGDONG PROVINCE, 510220

CHINA

8/31/2020 20-33134 (KRH) AnnTaylor, Inc. 1129 $ 2,543.00

Reason: No liability exists on the Debtors' books and records. The Debtor's have no record of the invoices or vendor described in this claim.

24 WOLF, NINA

2609 OAK GROVE STREET

BAKERSFIELD, CA 93311

1/14/2021 20-33113 (KRH) Ascena Retail Group, Inc. 5319 $ 308.00

Reason: No liability exists on the Debtors' books and records. The Claimant asserts liability which was satisfied as part of a Joint Stipulation of Class Action Settlement and Release which was approved 

by the Superior Court of the State of California (County of San Diego). Subsequently, the Debtors' paid the settlement amount as provided in the Settlement & Release.

Page 4 of 5

Retail Group, Inc. 20-33113 (KRH)

Thirtieth Omnibus Claims Objection

Schedule 1 - No Liability Claims

Case 20-33113-KRH Doc 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

Document Page 28 of 33
NAME DATE FILED CASE NUMBER DEBTOR CLAIM #

ASSERTED CLAIM 

AMOUNT

25 YANGZHOU DONGSHENG WOOL CO LTD

NO.12 MUYANG ROAD

YANGZHOU, 

CHINA

9/23/2020 20-33134 (KRH) AnnTaylor, Inc. 2153 $ 1,714.50

Reason: No liability exists on the Debtor's books and records on account of this claim.

TOTAL $ 469,917.12

Page 5 of 5

Retail Group, Inc. 20-33113 (KRH)

Thirtieth Omnibus Claims Objection

Schedule 1 - No Liability Claims

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253913863 v1 

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Schedule 2 

Substantive Duplicate Claims 

Case 20-33113-KRH Doc 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

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CLAIMS TO BE DISALLOWED REMAINING CLAIMS

NAME

DATE 

FILED

CASE NUMBER / 

DEBTOR CLAIM # CLAIM AMOUNT NAME

DATE 

FILED

CASE NUMBER / 

DEBTOR CLAIM # CLAIM AMOUNT

1 SILVEIRA, ISABELLA

222 STROME STREET

NEW ALBANY, OH 43054

01/16/21 Catherines, Inc.

20-33158 (KRH)

5499 $ 2,400.00 SILVEIRA, ISABELLA

222 STROME STREET

NEW ALBANY, OH 43054

08/06/20 Ascena Retail Group, Inc.

20-33113 (KRH)

406 $ 5,700.00

Reason: Claimant asserts administrative classification for pre-petition liability which duplicates the general unsecured liability for two invoices (031320 and 021420) asserted in the Remaining Claim.

2 SOPHIA VOURDOUKIS 

INC

345 DENNIS STREET

OCEANSIDE, NY 11572-

4313

01/15/21 Ascena Retail Group, Inc.

20-33113 (KRH)

5420 $ 4,950.00 VOURDOUKIS, SOPHIA

345 DENNIS STREET

OCEANSIDE, NY 11572

08/19/20 AnnTaylor Retail, Inc.

20-33132 (KRH)

303 $ 9,900.00

Reason: Claimant asserts administrative classification for pre-petition liability which duplicates the general unsecured liability asserted in the Remaining Claim.

Total $ 7,350.00 Total $ 15,600.00

Page 1 of 1

Retail Group, Inc. 20-33113 (KRH) 

Thirtieth Omnibus Claims Objection

Schedule 2 - Substantive Duplicate Claims

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Document Page 31 of 33
253913863 v1 

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Schedule 3 

Incorrect Priority Claim 

Case 20-33113-KRH Doc 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

Document Page 32 of 33
ASSERTED CLAIMS MODIFIED CLAIMS

NAME CLAIM# DEBTOR PRIORITY 

STATUS

AMOUNT DEBTOR PRIORITY 

STATUS

AMOUNT

1 KINDRED SYSTEMS INC.

169 STILLMAN STREET

SAN FRANCISCO, CA 94107

903 Ascena Retail Group, Inc. 503(b)(9) $21,600.00 Ascena Retail Group, Inc. 503(b)(9) $0.00

Ascena Retail Group, Inc. Unsecured $21,600.00

Subtotal $21,600.00

Reason: The invoices asserted in the proof of claim are for pre-petition services which should be reclassified to general unsecured.

TOTAL $ 21,600.00 TOTAL $ 21,600.00

Page 1 of 1

Retail Group, Inc. 20-33113 (KRH) 

Thirtieth Omnibus Claims Objection

Schedule 3 - Incorrect Priority Claim

Case 20-33113-KRH Doc 2406 Filed 09/03/21 Entered 09/03/21 19:30:56 Desc Main

Document Page 33 of 33