UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

(Richmond Division)

In re: *

TOYS “R” US, INC., et al.,

Debtors, 

*

*

Case No: 17-34665-KLP

Chapter 11

(Jointly Administered)

* * * * * * * * * * * 

NOTICE OF APPEARANCE AND REQUEST

FOR NOTICES AND SERVICE OF PAPERS

Please take notice that Whiteford, Taylor & Preston, LLP, and Paul Weiss Rifkind, 

Wharton & Garrison LLP hereby appear in this matter on behalf of the Ad Hoc Group of Taj 

Noteholders who are currently also noteholders under the DIP Note Indenture (the “Taj 

Noteholders”) and requests, in accord with the notice requirements of 11 U.S.C. §§102(1) and 

342, and Fed. R. Bankr. P. 2002, 3017, 3020, 4001 and 9007, that the undersigned be placed on 

any mailing matrix or service list that may be used for any purpose in this case and that all 

notices given or required to be given and all papers served or required to be served in this case be 

given to and served on the undersigned at the following address:

Christopher A. Jones, Esquire

Jennifer E. Wuebker, Esquire

WHITEFORD, TAYLOR & PRESTON, LLP

3190 Fairview Park Drive, Suite 800 

Falls Church, Virginia 22042

Brian S. Hermann, Esquire

Samuel E. Lovett, Esquire

Kellie Cairns, Esquire

PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP

1285 Avenue of the Americas 

New York, New York 10019-6064

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Please take further notice that the foregoing request includes not only the notices and 

papers referred to in the rules specified above, but also, without limitation, orders and notices of 

any petition, pleading, complaint, hearing, application, motion, request or demand, whether 

formal or informal, written or oral, or transmitted or conveyed by mail, delivery, telephone, 

telegraph, telex, telecopy or otherwise which effect or seek to affect in any way any rights or 

interests of creditors and parties in interest. 

This notice and demand is a “special appearance” and is not a consent to or waiver of the 

Association’s:

1. right under 28 U.S.C. § 157(c) to have final orders in proceedings reviewed de 

novo by a United States District Judge;

2. right to challenge the jurisdiction of the United States Bankruptcy Court, 

including, without limitation, its jurisdiction to adjudicate proceedings, whether by jury trial or 

otherwise, and notwithstanding the designation “core proceeding” under 28 U.S.C. § 157(b)(2);

3. right to a jury trial in any proceeding, whether available under state or federal law, 

notwithstanding the designation “core proceeding” under 28 U.S.C. § 157(b)(2);

4. right to have the reference withdrawn under 28 U.S.C. § 157(b)(2); and

5. all other rights, claims, actions, defenses, setoffs, recoupments or other matters to 

which the Taj Noteholders is entitled to by law, equity or agreement.

All those rights are expressly reserved without exception and without the purpose of 

confessing or conceding jurisdiction by the Taj Noteholders by this filing or by any other 

participation in the case by the Taj Noteholders. Unless otherwise expressly authorized, the 

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filing of this pleading does not authorize counsel to accept service of process on behalf of the Taj 

Noteholders. 

Dated: September 20, 2017 Respectfully submitted,

/s/ Christopher A. Jones

WHITEFORD, TAYLOR & PRESTON, LLP

Christopher A. Jones (VSB # 40064)

Jennifer E. Wuebker (VSB # 91184)

3190 Fairview Park Drive, Suite 800

Falls Church, Virginia 22042

703.280.9260

703.280.9139 (facsimile)

Email: cajones@wtplaw.com

jwuebker@wtplaw.com

Brian S. Hermann (pro hac vice pending)

Samuel E. Lovett (pro hac vice pending)

Kellie A. Cairns (pro hac vice pending)

Paul, Weiss, Rifkind, Wharton & Garrison LLP

1285 Avenue of the Americas 

New York, New York 10019-6064

212.373.3000

212.373.2053 (facsimile)

Email: bhermann@paulweiss.com

slovett@paulweiss.com

kcairns@paulweiss.com

Counsel for Ad Hoc Group of Taj Noteholders 

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CERTIFICATE OF SERVICE

I hereby certify that on this September 20, 2017, the foregoing Notice of Appearance and 

Request for Notices and Service of Papers was filed and served via the Court’s Electronic Case 

Filing System on all parties receiving such notification.

/s/ Christopher A. Jones

Counsel

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