HTML Document View

Full title: Certification of Counsel Regarding Stipulation By and Between the Comcar Wind-Down Trust, Travelers Casualty and Surety Company of America, Andi Dizdari and Gazmend Avdulla Regarding Proofs of Claims Nos. 797 and 798 (related document(s)1284, 1336, 1348) Filed by Comcar Wind-Down Trust. (Attachments: # 1 Exhibit A) (Brown, Stuart) (Entered: 07/16/2021)

Document posted on Jul 15, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

I, Stuart M. Brown, an attorney with DLA Piper LLP (US), as counsel to the Comcar Wind-Down Trust (the “Wind-Down Trust”), as successor in interest to Comcar Industries, Inc. and its affiliated debtors (collectively, the “Debtors”) in the above-captioned chapter 11 cases, hereby certify the following: 1.Andi Dizdari and Gazmend Avdulla (together, the “Claimants”) assert personal injury claims against Debtor CTL Transportation, LLC arising out of postpetition occurrences.The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are: 9th Place Newberry, LLC (0359); 16th Street Pompano Beach, LLC (0278); CCC Spotting, LLC (0342); CCC Transportation, LLC (1058); Charlotte Avenue Auburndale, LLC (2179); Coastal Transport, Inc. (2918); Coastal Transport Logistics, LLC (7544); Comcar Industries, Inc. (8221); Comcar Logistics, LLC (2338); Comcar Properties, Inc. (9545); Commercial Carrier Corporation (8582); Commercial Carrier Logistics, LLC (7544); Commercial Truck and Trailer Sales Inc. (0722); Cortez Blvd.Brooksville, LLC (2210); CT Transportation, LLC (0997); CTL Distribution, Inc. (7383); CTL Distribution Logistics, LLC (7506); CTL Transportation, LLC (0782); CTTS Leasing, LLC (7466); Detsco Terminals, Inc. (9958); Driver Services, Inc. (3846); East Broadway Tampa, LLC (2233); East Columbus Drive Tampa, LLC (3995); Fleet Maintenance Services, LLC (1410); MCT Transportation, LLC (0939); Midwest Coast Logistics, LLC (7411); Midwest Coast Transport, Inc. (0045); New Kings Road Jacksonville, LLC (4797); Old Winter Haven Road Auburndale, LLC (4738); W. Airport Blvd.Sanford, LLC (0462); Willis Shaw Logistics, LLC (7341); WSE Transportation, LLC (0866).

List of Tables

Document Contents

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ---------------------------------------------------------------x : Chapter 11 In re: : : Case No. 20-11120 (LSS) COMCAR INDUSTRIES, INC., et al.,1 : : (Jointly Administered) Debtors. : : Related D.I.: 1284, 1336, 1348 ---------------------------------------------------------------x CERTIFICATION OF COUNSEL REGARDING STIPULATION BY AND BETWEEN THE COMCAR WIND-DOWN TRUST, TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA, ANDI DIZDARI AND GAZMEND AVDULLA REGARDING PROOFS OF CLAIMS NOS. 797 AND 798 I, Stuart M. Brown, an attorney with DLA Piper LLP (US), as counsel to the Comcar Wind-Down Trust (the “Wind-Down Trust”), as successor in interest to Comcar Industries, Inc. and its affiliated debtors (collectively, the “Debtors”) in the above-captioned chapter 11 cases, hereby certify the following: 1. Andi Dizdari and Gazmend Avdulla (together, the “Claimants”) assert personal injury claims against Debtor CTL Transportation, LLC arising out of postpetition occurrences. 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are: 9th Place Newberry, LLC (0359); 16th Street Pompano Beach, LLC (0278); CCC Spotting, LLC (0342); CCC Transportation, LLC (1058); Charlotte Avenue Auburndale, LLC (2179); Coastal Transport, Inc. (2918); Coastal Transport Logistics, LLC (7544); Comcar Industries, Inc. (8221); Comcar Logistics, LLC (2338); Comcar Properties, Inc. (9545); Commercial Carrier Corporation (8582); Commercial Carrier Logistics, LLC (7544); Commercial Truck and Trailer Sales Inc. (0722); Cortez Blvd. Brooksville, LLC (2210); CT Transportation, LLC (0997); CTL Distribution, Inc. (7383); CTL Distribution Logistics, LLC (7506); CTL Transportation, LLC (0782); CTTS Leasing, LLC (7466); Detsco Terminals, Inc. (9958); Driver Services, Inc. (3846); East Broadway Tampa, LLC (2233); East Columbus Drive Tampa, LLC (3995); Fleet Maintenance Services, LLC (1410); MCT Transportation, LLC (0939); Midwest Coast Logistics, LLC (7411); Midwest Coast Transport, Inc. (0045); New Kings Road Jacksonville, LLC (4797); Old Winter Haven Road Auburndale, LLC (4738); W. Airport Blvd. Sanford, LLC (0462); Willis Shaw Logistics, LLC (7341); WSE Transportation, LLC (0866). The corporate headquarters and the mailing address for the Debtors listed above is 8800 Baymeadows Way West, Suite 200, Jacksonville, Florida 32256.

1

2. On April 26, 2021, the Court entered the Amended Order Approving Stipulation By and Between the Debtors and Andi Dizdari and Gazmend Avdulla Regarding Proofs of Claim Nos. 797 and 798 [D.I. 1336] (the “Amended Order”). 3. On March 10, 2021, Travelers Casualty and Insurance Company of America (“Travelers”) filed its motion to reconsider the Amended Order [D.I. 1348]. 4. The Wind-Down Trust, the Claimants and Travelers have agreed to enter into theStipulation By and Between the Comcar Wind-Down Trust, Travelers Casualty and Insurance Company of America, Andi Dizdari and Gazmend Avdulla Regarding Proofs of Claim Nos. 797 and 798 (the “Stipulation”), which is annexed as Exhibit 1 to the proposed order. The proposed order is attached hereto as Exhibit A (the “Proposed Order”). [Remainder of Page Intentionally Left Blank]

2

WHEREFORE, the Wind-Down Trust respectfully requests that the Court enter the Proposed Order, attached hereto as Exhibit A, approving the Stipulation, and grant such other and further relief that the Court deems just and proper. Dated: July 16, 2021 Respectfully submitted, Wilmington, Delaware DLA PIPER LLP (US) /s/ Stuart M. Brown Stuart M. Brown (DE 4050) 1201 North Market Street, Suite 2100 Wilmington, Delaware 19801 Telephone: (302) 468-5700 Facsimile: (302) 394-2341 Email: stuart.brown@us.dlapiper.com -and- Jamila Justine Willis (admitted pro hac vice) 1251 Avenue of the Americas New York, New York 10020 Telephone: (212) 335-4500 Facsimile: (212) 335-4501 Email: jamila.willis@us.dlapiper.com Counsel to the Wind-Down Trust

3