Steven N. Serajeddini, P.C. (pro hac vice admission pending) Michael A. Condyles (VA 27807) 

KIRKLAND & ELLIS LLP Peter J. Barrett (VA 46179) 

KIRKLAND & ELLIS INTERNATIONAL LLP Jeremy S. Williams (VA 77469) 

601 Lexington Avenue Brian H. Richardson (VA 92477) 

New York, New York 10022 KUTAK ROCK LLP

Telephone: (212) 446-4800 901 East Byrd Street, Suite 1000

Facsimile: (212) 446-4900 Richmond, Virginia 23219-4071 

 Telephone: (804) 644-1700 

-and- Facsimile: (804) 783-6192 

 

David L. Eaton (pro hac vice admission pending) 

Jaimie Fedell (pro hac vice admission pending) 

KIRKLAND & ELLIS LLP

KIRKLAND & ELLIS INTERNATIONAL LLP

300 North La Salle Street 

Chicago, Illinois 60654 

Telephone: (312) 862-2000

Facsimile: (312) 862-2200

Proposed 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 

)

LE TOTE, INC., ) Case No. 20-33332 

)

 Debtor. )

)

Tax I.D. No. 45-5163722 ) 

)

In re: ) Chapter 11 

)

FRENCH TOTE LLC, ) Case No. 20-33329 

)

 Debtor. )

)

Tax I.D. No. 84-3457492 )

)

In re: ) Chapter 11 

)

LE TOTE, LLC, ) Case No. 20-33330 

)

 Debtor. )

)

Tax I.D. No. 84-4787857 )

Case 20-33330-KLP Doc 3 Filed 08/02/20 Entered 08/02/20 18:14:46 Desc Main

Document Page 1 of 15
2 

)

In re: ) Chapter 11 

)

LORD & TAYLOR LLC, ) Case No. 20-33331 

)

 Debtor. )

)

Tax I.D. No. 20-5344961 )

 ) 

In re: ) Chapter 11 

)

LT CARD COMPANY LLC, ) Case No. 20-33328 

)

 Debtor. )

)

Tax I.D. No. 26-0192954 )

DEBTORS’ MOTION FOR ENTRY OF AN 

ORDER (I) DIRECTING JOINT ADMINISTRATION OF 

CHAPTER 11 CASES AND (II) GRANTING RELATED RELIEF 

The above-captioned debtors and debtors in possession (collectively, the “Debtors”)1

respectfully state as follows in support of this motion (this “Motion”): 

Relief Requested 

1. The Debtors seek entry of an order, substantially in the form attached hereto as 

Exhibit A (the “Order”): (a) directing procedural consolidation and joint administration of these 

chapter 11 cases; and (b) granting related relief. The Debtors request that one file and one docket 

be maintained for all jointly administered cases under the case of Le Tote, Inc. (the direct or 

indirect parent company for each of the Debtors) and that the cases be administered under a 

consolidated caption, as follows: 

 

1

 A detailed description of the Debtors and their business, and the facts and circumstances supporting the Debtors’ 

chapter 11 cases, are set forth in greater detail in the Declaration of Ed Kremer, Chief Restructuring Officer, of 

Le Tote, Inc., in Support of Chapter 11 Petitions and First Day Motions (the “First Day Declaration”), filed 

contemporaneously with the Debtors’ voluntary petitions for relief filed under chapter 11 of title 11 of the United 

States Code (the “Bankruptcy Code”), on the date hereof (the “Petition Date”). Capitalized terms used, but not 

otherwise defined in this Motion shall have the meanings ascribed to them in the First Day Declaration. 

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3 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

 ) 

In re: ) Chapter 11 

 ) 

LE TOTE, INC., et al.,

1

 ) Case No. 20-33332 (___) 

 ) 

 Debtors. ) (Jointly Administered) 

 ) 

___________________________________________________ 

1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 

number, are set forth in the Debtors’ Motion for Entry of an Order (I) Directing Joint Administration of 

Chapter 11 Cases and (II) Granting Related Relief filed contemporaneously herewith. The location of the 

Debtors’ service address is 250 Vesey Street, 22nd Floor, New York, New York 10281.

2. The Debtors further request that this Court (as defined below) order that the 

foregoing caption satisfies the requirements set forth in section 342(c)(1) of the Bankruptcy Code. 

3. The Debtors also request that a docket entry, substantially similar to the following, 

be entered on the docket of each of the Debtors other than Le Tote, Inc. to reflect the joint 

administration of these chapter 11 cases: 

An order has been entered in accordance with rule 1015(b) of the Federal 

Rules of Bankruptcy Procedure and rule 1015-1 of the Local Bankruptcy 

Rules for the United States Bankruptcy Court for the Eastern District of 

Virginia directing joint administration for procedural purposes only of the 

chapter 11 cases of: Le Tote, Inc., Case No. 20-33332; French Tote LLC, 

Case No. 20-33329; Le Tote, LLC, Case No. 20-33330; 

Lord & Taylor LLC, Case No. 20-33331; LT Card Company LLC, Case 

No. 20-33328. The docket in Case No. 20-33332 should be consulted for 

all matters affecting these cases. 

4. Finally, the Debtors seek authority to file the monthly operating reports required by 

the Operating Guidelines and Reporting Requirements of the United States Trustee for Chapter 11 

Debtors in Possession and Chapter 11 Trustees, issued by the Office of the United States Trustee 

for the Eastern District of Virginia (the “U.S. Trustee”), on a consolidated basis, but the Debtors 

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4 

shall track and break out disbursements on a debtor-by-debtor basis in each monthly operating 

report. 

Jurisdiction and Venue 

5. 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 Debtors confirm their 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 Motion 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. 

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

7. The bases for the relief requested herein are section 105(a) of the Bankruptcy Code, 

Bankruptcy Rule 1015(b), and rules 1015-1 and 9013-1 of the Local Rules of the United States 

Bankruptcy Court for the Eastern District of Virginia (the “Local Bankruptcy Rules”). 

Background 

8. The Debtors are the combination of Le Tote—a venture-backed fashion rental 

subscription service founded in 2012 in San Francisco—and Lord & Taylor—the iconic luxury 

retailer which traces its origins to 1826 in New York. Le Tote purchased Lord & Taylor in a 

transaction which closed in November 2019. The Debtors operate both an online, 

subscription-based clothing rental service and a full-service fashion retailer with 

38 brick-and-mortar locations and a robust e-commerce platform. In response to the COVID-19 

pandemic the Debtors temporarily closed all retail locations in March 2020, although they continue 

to operate the Le Tote and Lord & Taylor websites. The Debtors reported revenue of 

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5 

approximately $253.5 million for 2019. As of the Petition Date, the Debtors have approximately 

651 employees and funded debt obligations of approximately $137.9 million. 

9. On the Petition Date, each of the Debtors filed a voluntary petition for relief under 

chapter 11 of the Bankruptcy Code. The Debtors are operating their business and managing their 

properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 

No request for the appointment of a trustee or examiner has been made in these chapter 11 cases, 

and no committees have been appointed or designated. 

Basis for Relief 

10. Bankruptcy Rule 1015(b) provides, in pertinent part, that “[i]f . . . two or more 

petitions are pending in the same court by or against . . . a debtor and an affiliate, the court may 

order a joint administration of the estates.” Fed. R. Bankr. P. 1015. The five (5) Debtor entities 

that commenced chapter 11 cases are “affiliates” as that term is defined in section 101(2) of the 

Bankruptcy Code. Accordingly, the Bankruptcy Code and Bankruptcy Rules authorize the Court 

to grant the relief requested herein. 

11. Further, Local Bankruptcy Rule 1015-1 provides additional authority for the Court 

to order joint administration of these chapter 11 cases: 

In all joint petitions filed with the Court, the case will be 

administered through joint administration of the estates unless the 

trustee or other interested party files an objection to joint 

administration within 14 days after the meeting of creditors and 

gives notice of a hearing date on such objection. 

Local Bankr. R. 1015-1. 

12. Joint administration is generally non-controversial, and courts in this jurisdiction 

routinely order joint administration in cases with multiple related debtors. See, e.g., In re Intelsat 

S.A., No. 20-32399 (KLP) (Bankr. E.D. Va. May 15, 2020) (directing joint administration of 

chapter 11 cases); In re Pier 1 Imports, Inc., No. 20-30805 (KRH) (Bankr. E.D. Va. Feb. 18, 2020) 

Case 20-33330-KLP Doc 3 Filed 08/02/20 Entered 08/02/20 18:14:46 Desc Main

Document Page 5 of 15
6 

(same); In re Gemstone Solutions Group, Inc., No. 19-30258 (KLP) (Bankr. E.D. Va. Jan. 17, 

2019) (same); In re Toys “R” Us, Inc., No. 17-34665 (KLP) (Bankr. E.D. Va. Sept. 19, 2017) 

(same); In re The Gymboree Corp., No. 17-32986 (KLP) (Bankr. E.D. Va. June 2, 2017) (same).2

13. Given the integrated nature of the Debtors’ operations, joint administration of these 

chapter 11 cases will provide significant administrative convenience without harming the 

substantive rights of any party in interest. Many of the motions, hearings, and orders in these 

chapter 11 cases will affect each Debtor entity. The entry of an order directing joint administration 

of these chapter 11 cases will reduce fees and costs by avoiding duplicative filings and objections. 

Joint administration also will allow the U.S. Trustee and all parties in interest to monitor these 

chapter 11 cases with greater ease and efficiency. 

14. Moreover, joint administration will not adversely affect the Debtors’ respective 

constituencies because this Motion seeks only administrative, not substantive, consolidation of the 

Debtors’ estates. Parties in interest will not be harmed by the relief requested; instead, parties in 

interest will benefit from the cost reductions associated with the joint administration of these 

chapter 11 cases. Accordingly, the Debtors submit that the joint administration of these 

chapter 11 cases is in the best interests of their estates, their creditors, and all other parties 

in interest. 

Waiver of Memorandum of Points and Authorities 

15. The Debtors respectfully request that this Court treat this Motion as a written 

memorandum of points and authorities or waive any requirement that this Motion be accompanied 

 

2

 Because of the voluminous nature of the orders cited herein, such orders have not been attached to this Motion. 

Copies of these orders are available upon request to the Debtors’ proposed counsel. 

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7 

by a written memorandum of points and authorities as described in Local Bankruptcy 

Rule 9013-1(G). 

Notice 

16. The Debtors will provide notice of this Motion via first class mail, facsimile or 

email (where available) to: (a) the Office of the United States Trustee for the Eastern District of 

Virginia, Attn: Kathryn R. Montgomery, Shannon F. Pecoraro, and Lynn A. Kohen; (b) the 

holders of the 30 largest unsecured claims against the Debtors (on a consolidated basis); (c) the 

agents under the Debtors’ prepetition secured facilities and counsel thereto; (d) counsel to HBC 

US Holdings LLC and HBC US Propco Holdings LLC; (e) the Internal Revenue Service; (f) the 

office of the attorneys general for the states in which the Debtors operate; (g) the United States 

Attorney’s Office for the Eastern District of Virginia; (h) the Securities and Exchange 

Commission; (i) the National Association of Attorneys General; and (j) any party that has 

requested notice pursuant to Bankruptcy Rule 2002 (collectively, the “Notice Parties”). The 

Debtors submit that, in light of the nature of the relief requested, no other or further notice need 

be given. 

No Prior Request 

17. No prior request for the relief sought in this Motion has been made to this or any 

other court. 

[Remainder of page intentionally left blank] 

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Document Page 7 of 15
WHEREFORE, the Debtors respectfully request that the Court enter the Order, 

substantially in the form attached hereto as Exhibit A, granting the relief requested herein and 

such other relief as the Court deems appropriate under the circumstances. 

 

Dated: August 2, 2020 

 

/s/ Jeremy S. Williams 

KUTAK ROCK LLP KIRKLAND & ELLIS LLP 

Michael A. Condyles (VA 27807) KIRKLAND & ELLIS INTERNATIONAL LLP

Peter J. Barrett (VA 46179) Steven N. Serajeddini, P.C. 

Jeremy S. Williams (VA 77469) (pro hac vice admission pending) 

Brian H. Richardson (VA 92477) 601 Lexington Avenue 

901 East Byrd Street, Suite 1000 New York, New York 10022 

Richmond, Virginia 23219-4071 Telephone: (212) 446-4800 

Telephone: (804) 644-1700 Facsimile: (212) 446-4900 

Facsimile: (804) 783-6192 Email: steven.serajeddini@kirkland.com 

Email: Michael.Condyles@KutakRock.com 

 Peter.Barrett@KutakRock.com -and- 

 Jeremy.Williams@KutakRock.com 

 Brian.Richardson@KutakRock.com KIRKLAND & ELLIS LLP

 KIRKLAND & ELLIS INTERNATIONAL LLP

Proposed Co-Counsel to the Debtors David L. Eaton (pro hac vice admission pending) 

 Jaimie Fedell 

300 North La Salle Street 

Chicago, Illinois 60654 

 Telephone: (312) 862-2000 

 Facsimile: (312) 862-2200 

 Email: david.eaton@kirkland.com 

 jaimie.fedell@kirkland.com 

 

Proposed Co-Counsel to the Debtors

 and Debtors in Possession

Case 20-33330-KLP Doc 3 Filed 08/02/20 Entered 08/02/20 18:14:46 Desc Main

Document Page 8 of 15
Exhibit A 

Proposed Order

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Document Page 9 of 15
Steven N. Serajeddini, P.C. (pro hac vice admission pending) Michael A. Condyles (VA 27807) 

KIRKLAND & ELLIS LLP Peter J. Barrett (VA 46179) 

KIRKLAND & ELLIS INTERNATIONAL LLP Jeremy S. Williams (VA 77469) 

601 Lexington Avenue Brian H. Richardson (VA 92477) 

New York, New York 10022 KUTAK ROCK LLP

Telephone: (212) 446-4800 901 East Byrd Street, Suite 1000

Facsimile: (212) 446-4900 Richmond, Virginia 23219-4071 

 Telephone: (804) 644-1700 

-and- Facsimile: (804) 783-6192 

 

David L. Eaton (pro hac vice admission pending) 

Jaimie Fedell (pro hac vice admission pending)

KIRKLAND & ELLIS LLP

KIRKLAND & ELLIS INTERNATIONAL LLP

300 North La Salle Street 

Chicago, Illinois 60654 

Telephone: (312) 862-2000

Facsimile: (312) 862-2200

Proposed 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 

)

LE TOTE, INC., ) Case No. 20-33332 

)

 Debtor. )

)

Tax I.D. No. 45-5163722 ) 

)

In re: ) Chapter 11 

)

FRENCH TOTE LLC, ) Case No. 20-33329 

)

 Debtor. )

)

Tax I.D. No. 84-3457492 )

)

In re: ) Chapter 11 

)

LE TOTE, LLC, ) Case No. 20-33330 

)

 Debtor. )

)

Tax I.D. No. 84-4787857 )

Case 20-33330-KLP Doc 3 Filed 08/02/20 Entered 08/02/20 18:14:46 Desc Main

Document Page 10 of 15
2 

)

In re: ) Chapter 11 

)

LORD & TAYLOR LLC, ) Case No. 20-33331 

)

 Debtor. )

)

Tax I.D. No. 20-5344961 )

 ) 

In re: ) Chapter 11 

)

LT CARD COMPANY LLC, ) Case No. 20-33328 

)

 Debtor. )

)

Tax I.D. No. 26-0192954 )

ORDER (I) DIRECTING JOINT ADMINISTRATION OF 

CHAPTER 11 CASES AND (II) GRANTING RELATED RELIEF 

Upon the motion (the “Motion”)1 of the above-captioned debtors and debtors in possession 

(collectively, the “Debtors”) for entry of an order (this “Order”), (a) directing the joint 

administration of the Debtors’ chapter 11 cases for procedural purposes only; and 

(b) granting related relief, all as more fully set forth in the Motion; and upon the 

First Day 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 this Court having found that 

it 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 Motion 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 Motion 

is in the best interests of the Debtors’ estates, their creditors, and other parties in interest; and this 

Court having found that the Debtors’ notice of the Motion and opportunity for a hearing on the 

 

1 Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Motion. 

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3 

Motion were appropriate under the circumstances and that no other notice need be provided; and 

this Court having reviewed the Motion and having heard the statements in support of the relief 

requested therein at a hearing before this Court (the “Hearing”); and this Court having determined 

that the legal and factual bases set forth in the Motion and at the Hearing 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 Motion is granted as set forth in this Order. 

2. The above-captioned chapter 11 cases are consolidated for procedural purposes 

only and shall be jointly administered by the Court under Case No. 20-33332 (___). 

3. The caption of the jointly administered cases should read as follows: 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

 ) 

In re: ) Chapter 11 

 ) 

LE TOTE, INC. et al.,

1

 ) Case No. 20-33332 (___) 

 ) 

 Debtors. ) (Jointly Administered) 

 ) 

___________________________________________________ 

1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 

number, are set forth in the Debtors’ Motion for Entry of an Order (I) Directing Joint Administration of 

Chapter 11 Cases and (II) Granting Related Relief filed contemporaneously herewith. The location of the 

Debtors’ service address is 250 Vesey Street, 22nd Floor, New York, New York 10281.

4. The foregoing caption satisfies the requirements set forth in section 342(c)(1) of 

the Bankruptcy Code. 

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4 

5. A docket entry, substantially similar to the following, shall be entered on the docket 

of each of the Debtors other than Le Tote, Inc. to reflect the joint administration of these chapter 11 

cases: 

An order has been entered in accordance with rule 1015(b) of the Federal 

Rules of Bankruptcy Procedure and rule 1015-1 of the Local Bankruptcy 

Rules for the United States Bankruptcy Court for the Eastern District of 

Virginia directing joint administration for procedural purposes only of the 

chapter 11 cases of: Le Tote, Inc., Case No. 20-33332; French Tote LLC, 

Case No. 20-33329; Le Tote, LLC, Case No. 20-33330; 

Lord & Taylor LLC, Case No. 20-33331; LT Card Company LLC, Case 

No. 20-33328. The docket in Case No. 20-33332 should be consulted for 

all matters affecting these cases.

6. The Debtors shall maintain, and the Clerk of the United States Bankruptcy Court 

for the Eastern District of Virginia shall keep, one consolidated docket, one file, and one 

consolidated service list for these chapter 11 cases. 

7. The Debtors are authorized to file the monthly operating reports required by the 

Operating Guidelines and Reporting Requirements of the United States Trustee for 

Chapter 11 Debtors in Possession and Chapter 11 Trustees, issued by the Office of the 

United States Trustee for the Eastern District of Virginia, on a consolidated basis, but the Debtors 

shall track and break out disbursements on a debtor-by-debtor basis in each monthly operating 

report. 

8. Nothing contained in the Motion or this Order shall be deemed or construed as 

directing or otherwise effecting a substantive consolidation of these chapter 11 cases, the Debtors, 

or the Debtors’ estates, and this Order shall be without prejudice to the rights of the Debtors to 

seek entry of an order substantively consolidating their respective cases. 

9. The requirement under Local Bankruptcy Rule 9013-1(G) to file a memorandum 

of law in connection with the Motion is waived. 

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5 

10. Notice of the Motion as provided therein shall be deemed good and sufficient notice 

of such Motion and the requirements of Bankruptcy Rule 6004(a) and the Local Bankruptcy Rules 

are satisfied by such notice. 

11. Notwithstanding Bankruptcy Rule 6004(h), the terms and conditions of this Order 

are immediately effective and enforceable upon its entry. 

12. The Debtors are authorized to take all actions necessary to effectuate the relief 

granted in this Order. 

13. 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/ Jeremy S. Williams 

Michael A. Condyles (VA 27807) 

Peter J. Barrett (VA 46179) 

Jeremy S. Williams (VA 77469) 

Brian H. Richardson (VA 92477)

KUTAK ROCK LLP

901 East Byrd Street, Suite 1000 

Richmond, Virginia 23219-4071 

Telephone: (804) 644-1700 

Facsimile: (804) 783-6192 

- and - 

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

KIRKLAND & ELLIS LLP 

KIRKLAND & ELLIS INTERNATIONAL LLP 

601 Lexington Avenue

New York, New York 10022

Telephone: (212) 446-4800 

Facsimile: (212) 446-4900 

- and - 

David L. Eaton (pro hac vice admission pending) 

Jaimie Fedell (pro hac vice admission pending) 

KIRKLAND & ELLIS LLP

KIRKLAND & ELLIS INTERNATIONAL LLP

300 North La Salle Street 

Chicago, Illinois 60654 

Telephone: (212) 446-4800

Facsimile: (212) 446-4900

Proposed Co-Counsel to the Debtors and Debtors in Possession 

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/ Jeremy S. Williams 

 

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