4891-7268-8884.2

ROPES & GRAY LLP

Chris L. Dickerson (pro hac vice pending)

Rahmon J. Brown (pro hac vice pending) 

191 North Wacker Drive, 32nd Floor

Chicago, Illinois 60606

Telephone: (312) 845-1200 

Facsimile: (312) 845-5500

chris.dickerson@ropesgray.com

rahmon.brown@ropesgray.com

FOLEY & LARDNER LLP

Holland N. O’Neil (TX 14864700)

Mark C. Moore (TX 24074751)

Zachary C. Zahn (TX 24137675)

2021 McKinney Avenue, Suite 1600

Dallas, TX 75201

Telephone: (214) 999-3000

Facsimile: (214) 999-4667

honeil@foley.com

mmoore@foley.com

zzahn@foley.com

Proposed Counsel for the Debtors

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

In re:

TGI Friday’s Inc., et al.,

1

Debtors.

Chapter 11

Case No. 24-80069-sgj11

(Joint Administration Requested) 

AGENDA FOR FIRST DAY HEARINGS

ON NOVEMBER 4, 2024 AT 11:00 A.M. CENTRAL TIME

TGI Friday’s Inc. and its affiliated debtors and debtors in possession (each a “Debtor” and

collectively, the “Debtors”) hereby file their agenda for hearings on Monday, November 4, 2024

at 11:00 A.M. Central Time, before the Honorable Stacey G.C. Jernigan, U.S. Bankruptcy Judge 

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

number are: TGI Friday's Inc. (7117); TGI Friday's NY, LLC (2281); TGIF Holdings, LLC (7999); TGIF Midco, 

Inc. (7296); TGIF Parent, Inc. (1781); Burlington Towne Crossing, Inc. (7501); T G I Friday's of Greenbelt, Inc. 

(5617); T G I Friday's of Towson, Inc. (5450); T G I Friday's of Wisconsin, Inc. (7600); T.G.I. Friday's Marketing 

Advisory Council (6527); T.G.I. Friday's of Charles County, Inc. (3516); T.G.I. Friday's of Frederick County, 

Inc. (2547); T.G.I. Friday's of Harford County, Inc. (0072); T.G.I. Friday's of Washington County, Inc. (6174); 

TGI Friday's of Annapolis, Inc. (8315); TGI Friday's of Howard County, Inc. (0119); TGI Friday's of Rockville, 

Inc. (2004); TGI Friday's of Texas LLC (3931); TGI Friday's of the Rockies, Inc. (7885); TGIF/DFW Manager, 

LLC (N/A); TGIF/DFW Partner, LLC (N/A); TGIF/JDC Restaurant Development, LLC (N/A); WEBCO 

Products Incorporated (3014). The Debtors’ service address is 19111 North Dallas Parkway, Suite 200, Dallas, 

TX 75287.

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for the Northern District of Texas (the “Hearing”). The Debtors will ask the Court to consider the 

following:

I. Matters to be Heard:

A. Debtors’ Emergency Motion for Entry of an Order (I) Directing Joint 

Administration of Chapter 11 Cases and (II) Granting Related Relief [Docket 

No. 2] 

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 30];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

i. Status: This matter will go forward. The motion and proposed order have 

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

B. Notice of Designation as Complex Chapter 11 Bankruptcy Case [Docket No. 3] 

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 30];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

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C. Debtors’ Emergency Motion for Order Extending Time to File Schedules of 

Assets and Liabilities and Statements of Financial Affairs [Docket No. 14]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

D. Debtors’ Emergency Application for Entry of an Order Authorizing the 

Employment and Retention of Stretto Inc. as Claims, Noticing and Solicitation 

Agent Effective as of the Petition Date [Docket No. 10]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

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E. Debtors’ Emergency Motion for Entry of an Order (I) Authorizing the Debtors 

to File a Consolidated (A) Creditor Matrix and (B) Top 50 Creditors List, (II) 

Authorizing Redaction of Certain Personal Identification Information, and (III) 

Granting Related Relief [Docket No. 5]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

F. Debtors’ Emergency Motion for Entry of an Order (I) Authorizing Debtors to (A) 

Continue to Operate Their Cash Management System, (B) Honor Certain 

Prepetition Obligations Related Thereto, (C) Maintain Existing Business Forms, 

and (D) Continue Certain Intercompany Transactions, and (II) Granting Related 

Relief [Docket No. 13]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

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G. Debtors’ Emergency Motion for Entry of an Order (I)(A) Approving Debtors’ 

Proposed Form of Adequate Assurance of Payment for Future Utility Services, 

(B) Approving Debtors’ Proposed Procedures for Resolving Additional 

Assurance Requests, and (C) Prohibiting Utility Providers from Altering, 

Refusing, or Discontinuing Services; and (II) Granting Related Relief [Docket 

No. 12]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

H. Debtors’ Emergency Motion for Entry of an Order (I) Authorizing the Debtors 

to Maintain and Administer Their Existing Customer Programs and Honor 

Certain Prepetition Obligations Related Thereto and (II) Granting Related Relief

[Docket No. 15]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

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iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

I. Debtors’ Emergency Motion for Entry of an Order (I) Authorizing Debtors to (A) 

Maintain Existing Insurance Policies and Pay All Insurance Obligations Arising 

Thereunder, and (B) Renew, Supplement, Modify, or Purchase Insurance 

Coverage; (II) Authorizing Continuation and Renewal of Surety Bond Program; 

and (III) Granting Related Relief [Docket No. 6]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

J. Debtors’ Emergency Motion for Entry of an Order (I) Authorizing Debtors to 

Pay Prepetition Wages, Employee Benefits (A) Obligations, and Other 

Compensation and (B) Continue Employee Benefits Programs and Pay Related 

(C) Administrative Obligations, and (II) Grant Related Relief [Docket No. 11]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

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iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

K. Debtors’ Emergency Motion for Entry of an Order (I) Authorizing Debtors to 

Pay Certain Prepetition Taxes and Fees and (II) Granting Related Relief [Docket 

No. 20]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

L. Debtors’ Emergency Motion for Entry of Interim and Final Orders (I) 

Authorizing Debtor to Pay Certain Prepetition Claims of Certain Section 

503(b)(9) Claimants, and PACA/PASA Claimants (I) Authorizing Banks to 

Honor and Process Check and Electronic Transfer Requests, and (III) Granting 

Related Relief [Docket No. 18]; and

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

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iii. Status: This matter will go forward. This matter will go forward. The 

motion and proposed order have been transmitted to Elizabeth Young at the 

Office of the U.S. Trustee and there is no objection to entry of the proposed 

order as filed.

M. Debtors’ Emergency Motion for Entry of an Order (I) Authorizing Rejection of 

Certain Contracts and Nonresidential Real Property Leases, (II) Abandoning 

Certain Personal Property, and (III) Granting Related Relief [Docket No. 7] 

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

N. Debtors’ Emergency Motion for Entry of an Order (I) Authorizing and 

Approving Procedures to Reject Executory Contracts and Unexpired Leases and 

(II) Granting Related Relief [Docket No. 9] 

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

b. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

c. Notice of First Day Hearings [Docket No. 27]; and

d. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

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iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

O. Debtors’ Emergency Motion for Entry of Interim and Final Orders (I) 

Authorizing the Debtors to (A) Obtain Postpetition Financing and (B) Use Cash 

Collateral, (II) Granting Liens and Providing Claims with Superpriority 

Administrative Expense Status, (III) Modifying the Automatic Stay, (IV) 

Scheduling a Final Hearing and (V) Granting Related Relief [Docket No. 17, 19]

i. Related Documents:

a. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Emergency Motion for Entry of 

Interim and Final Orders (I) Authorizing the Debtors to (A) Obtain 

Postpetition Financing and (B) Use Cash Collateral, (II) Granting 

Liens and Providing Claims with Superpriority Administrative 

Expense Status, (III) Modifying the Automatic Stay, (IV) Scheduling 

a Final Hearing and (V) Granting Related Relief [Docket No. 26];

b. Declaration of Kyle Richter, Chief Restructuring Officer of the 

Debtors, in Support of the Debtors’ Chapter 11 Petitions and First 

Day Motions [Docket No. 28];

c. Certificate of Conference Regarding Debtors’ Emergency First Day 

Motions [Docket No. 29];

d. Notice of First Day Hearings [Docket No. 27]; and

e. Certificate of Service [Docket No. ##] (to be filed prior to hearings).

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The motion and proposed order have

been transmitted to Elizabeth Young at the Office of the U.S. Trustee and 

there is no objection to entry of the proposed order as filed.

II. Witness and Exhibits Lists:

A. Debtors’ Witness and Exhibit List on First Day Hearings [Docket No. 32] 

[Remainder of Page Intentionally Left Blank]

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The Debtors reserve the right to amend this Notice of Agenda as appropriate.

Dated: November 3, 2024 Respectfully submitted by:

/s/ Holland N. O’Neil 

FOLEY & LARDNER LLP

Holland N. O’Neil (TX 14864700)

Mark C. Moore (TX 24074751)

Zachary C. Zahn (TX 24137675)

2021 McKinney Avenue, Suite 1600

Dallas, TX 75201

Telephone: (214) 999-3000

Facsimile: (214) 999-4667

honeil@foley.com

mmoore@foley.com

zzahn@foley.com

- and -

ROPES & GRAY LLP

Chris L. Dickerson (pro hac vice pending)

Rahmon J. Brown (pro hac vice pending)

191 North Wacker Drive, 32nd Floor

Chicago, IL 60606

Telephone: (312) 845-1200 

Facsimile: (312) 845-5500

chris.dickerson@ropesgray.com

rahmon.brown@ropesgray.com

 

Proposed Counsel to the Debtors 

CERTIFICATE OF SERVICE

I certify that on November 3, 2024, a true and correct copy of the foregoing document was 

served electronically by the Court’s PACER system. 

/s/ Zachary C. Zahn 

Zachary C. Zahn

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