1

Stoli Group (USA), LLC (“Stoli USA”) and Kentucky Owl, LLC (“KO”), as debtors and 

debtors in possession (collectively, the “Debtors”), hereby file their amended agenda for hearings 

on Tuesday, December 3, 2024, at 9:30 A.M. Central Time, before the Honorable Scott W. 

Everett, U.S. Bankruptcy Judge for the Northern District of Texas (the “Hearing”). The Debtors 

will ask the Court to consider the following:

1 The Debtors in these Chapter 11 Cases, along with the last four digits of each Debtor’s federal identification number, 

are Stoli Group (USA), LLC (5602) and Kentucky Owl, LLC (3826). The Debtors’ address is 135 East 57th Street, 

9th Floor, New York City, New York.

Holland N. O’Neil (TX 14864700)

Stephen A. Jones (TX 24101270)

Mary Rofaeil (TX 24119467)

Zachary C. Zahn (TX 24137675)

FOLEY & LARDNER LLP

2021 McKinney Avenue, Suite 1600

Dallas, TX 75201

Telephone: (214) 999-3000

Facsimile: (214) 999-4667

honeil@foley.com

sajones@foley.com

mary.rofaeil@foley.com

zzahn@foley.com

PROPOSED COUNSEL TO DEBTORS

AND DEBTORS IN POSSESSION

Ann Marie Uetz (pro hac vice forthcoming)

FOLEY & LARDNER LLP

500 Woodward Avenue, Suite 2700

Detroit, MI 48226-3489

Telephone: (313) 234-7100

Facsimile: (313) 234-2800

auetz@foley.com

Michael J. Small (pro hac vice forthcoming)

FOLEY & LARDNER LLP

321 North Clark Street, Suite 3000

Chicago, IL 60654-4762

Telephone: (312) 832-4500

Facsimile: (312) 832-4700

msmall@foley.com

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

In re: 

Stoli Group (USA), LLC, et al.,

1

Debtors.

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Chapter 11

Case No.: 24-80146-swe11

(Joint Administration Requested)

AMENDED AGENDA FOR MATTERS SCHEDULED FOR

FIRST-DAY HEARING TO BE HELD ON DECEMBER 3, 2024, AT 9:30 A.M.

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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. 3; Filed on 11/27/2024]

i. Related Documents:

a. Declaration of Chris Caldwell in Support of First Day Motions

[Docket No. 11];

b. Request for Emergency Consideration of First Day Matters [Docket 

No. 12];

c. Notice of First Day Hearings [Docket No. 13]; and

d. Certificate of Service [Docket No. 22].

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. At this time, no objections have been 

filed or asserted concerning the motion or the Court’s entry of the proposed 

order as filed.

B. Notice of Designation as Complex Chapter 11 Bankruptcy Case [Docket No. 4; 

Filed on 11/27/2024]

i. Related Documents:

a. Declaration of Chris Caldwell in Support of First Day Motions

[Docket No. 11];

b. Request for Emergency Consideration of First Day Matters [Docket 

No. 12];

c. Notice of First Day Hearings [Docket No. 13]; 

d. Certificate of Service [Docket No. 22]; and

e. Notice of Filing of Revised Proposed Order Granting Chapter 11 

Complex Case Treatment [Docket No. 26].

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The Debtors amended the original 

proposed order to incorporate omnibus hearing dates and filed a notice of 

revised proposed order. [See Docket No. 26].

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

to Serve a Consolidated List of Creditors; (II) Authorizing the Debtors to Redact 

Certain Personal Identification Information; (III) Approving the Form and 

Manner of Notifying Creditors of the Commencement of the Debtors’ Chapter 11 

Cases and Bar Dates; and (IV) Granting Related Relief [Docket No. 5; Filed on 

11/27/2024]

i. Related Documents:

a. Declaration of Chris Caldwell in Support of First Day Motions

[Docket No. 11];

b. Request for Emergency Consideration of First Day Matters [Docket 

No. 12];

c. Notice of First Day Hearings [Docket No. 13]; and

d. Certificate of Service [Docket No. 22]; and

e. Notice of Filing of Revised Proposed Order (I) Authorizing the 

Debtors to Serve a Consolidated List of Creditors, (II) Authorizing 

the Debtors to Redact Certain Personal Identification Information, 

(III) Approving the Form and Manner of Notifying Creditors of the 

Commencement of the Debtors’ Chapter 11 Cases and Bar Dates, 

and (IV) Granting Related Relief [Docket No. 27].

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The Debtors received informal 

comments from the United States Trustee regarding the original proposed 

order and addressed such comments via a revised proposed order. [See

Docket No. 27].

D. Debtors’ Emergency Application for Entry of Interim and Final Orders

Authorizing the Employment and Retention of Stretto, Inc. as Claims, Noticing,

and Solicitation Agent Effective as of the Petition Date [Docket No. 6; Filed on 

11/27/2024]

i. Related Documents:

a. Stretto Services Agreement [Docket No. 6-3];

b. Declaration of Sheryl Betance in Support of Debtors’ Emergency 

Application for Entry of Interim and Final Orders Authorizing the 

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

Solicitation Agent Effective of the Petition Date [Docket No. 6-4];

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c. Declaration of Chris Caldwell in Support of First Day Motions

[Docket No. 11];

d. Request for Emergency Consideration of First Day Matters [Docket 

No. 12];

e. Notice of First Day Hearings [Docket No. 13];

f. Certificate of Service [Docket No. 22]; and

g. Notice of Filing of Revised Proposed Interim Order Authorizing the 

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

Solicitation Agent Effective as of the Petition Date [Docket No. 28].

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The Debtors received informal 

comments from the United States Trustee regarding the original proposed 

order and addressed such comments via a revised proposed order. [See

Docket No. 28].

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

Assets and Liabilities and Statements of Financial Affairs [Docket No. 7; Filed 

on 11/27/2024]

i. Related Documents:

a. Declaration of Chris Caldwell in Support of First Day Motions

[Docket No. 11];

b. Request for Emergency Consideration of First Day Matters [Docket 

No. 12];

c. Notice of First Day Hearings [Docket No. 13];

d. Certificate of Service [Docket No. 22]; and

e. Notice of Filing of Revised Proposed Order Granting Emergency 

Motion for Order Extending Time to File Schedules of Assets and 

Liabilities and Statements of Financial Affairs [Docket No. 25].

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The Debtors received informal 

comments from the United States Trustee regarding the original proposed 

order and addressed such comments via a revised proposed order. [See

Docket No. 25].

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

to (A) Pay Prepetition Wages, Salaries, Other Compensation, and Reimbursable 

Expenses, (B) Continue Employee Benefits Programs, and (II) Granting Related 

Relief [Docket No. 8; Filed on 11/29/2024]

i. Related Documents:

a. Declaration of Chris Caldwell in Support of First Day Motions

[Docket No. 11];

b. Request for Emergency Consideration of First Day Matters [Docket 

No. 12];

c. Notice of First Day Hearings [Docket No. 13]; and

d. Certificate of Service [Docket No. 22].

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. At this time, no objections have been 

filed or asserted concerning the motion or the Court’s entry of the proposed 

order as filed.

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

Continue to Operate Their Cash Management System and (II) Granting Related 

Relief [Docket No. 9; Filed on 11/29/2024]

i. Related Documents:

a. Declaration of Chris Caldwell in Support of First Day Motions

[Docket No. 11];

b. Request for Emergency Consideration of First Day Matters [Docket 

No. 12];

c. Notice of First Day Hearings [Docket No. 13]; and

d. Certificate of Service [Docket No. 22]; and

e. Notice of Filing of Revised Proposed Order Granting Debtors’ 

Emergency Motion for Entry of an Order (I) Authorizing the 

Debtors to Continue to Operate Their Cash Management System 

and (II) Granting Related Relief [Docket No. 29].

ii. Response Deadline: Prior to the Hearing.

iii. Status: This matter will go forward. The Debtors received informal 

comments from the United States Trustee and Wells Fargo Bank NA 

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regarding the original proposed order and addressed such comments via a 

revised proposed order. [See Docket No. 29].

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

Authorizing the Debtors to Use Cash Collateral, (II) Granting Adequate 

Protection; (III) Modifying the Automatic Stay; (IV) Scheduling a Final Hearing 

and; (V) Granting Related Relief [Docket No. 10; Filed on 11/29/2024]

i. Related Documents:

a. Declaration of Chris Caldwell in Support of First Day Motions

[Docket No. 11];

b. Cash Collateral Budget [Docket No. 21];

c. Request for Emergency Consideration of First Day Matters [Docket 

No. 12];

d. Notice of First Day Hearings [Docket No. 13]; and

e. Certificate of Service [Docket No. 22].

ii. Response Deadline: Prior to the Hearing.

iii. Responses:

a. Demand for Adequate Protection, Limited Objection to Cash 

Collateral Motion and Reservation of Rights of Fifth Third Bank, 

National Association, as Senior Secured Lender [Docket No. 24].

iv. Status: This matter will go forward.

II. Witness and Exhibits Lists:

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

23].

[Signature Page to Follow]

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DATED: December 2, 2024 Respectfully submitted by:

/s/ Holland N. O’Neil

Holland N. O’Neil (TX 14864700)

Stephen A. Jones (TX 24101270)

Mary Rofaeil (TX 24119467)

Zachary C. Zahn (TX 24137675)

FOLEY & LARDNER LLP

2021 McKinney Avenue, Suite 1600

Dallas, TX 75201

Telephone: (214) 999-3000

Facsimile: (214) 999-4667

honeil@foley.com

sajones@foley.com

mary.rofaeil@foley.com

zzahn@foley.com

-andAnn Marie Uetz (pro hac vice forthcoming)

FOLEY & LARDNER LLP

500 Woodward Avenue, Suite 2700

Detroit, MI 48226-3489

Telephone: (313) 234-7100

Facsimile: (313) 234-2800

auetz@foley.com 

-andMichael J. Small (pro hac vice forthcoming)

FOLEY & LARDNER LLP

321 North Clark Street, Suite 3000

Chicago, IL 60654-4762

Telephone: (312) 832-4500

Facsimile: (312) 832-4700

msmall@foley.com

PROPOSED COUNSEL TO DEBTORS

AND DEBTORS IN POSSESSION

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CERTIFICATE OF SERVICE

I hereby certify that, on December 2, 2024, a true and correct copy of the foregoing 

document was served electronically by the Court’s PACER system. 

/s/ Stephen A. Jones

Stephen A. Jones

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