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Full title: Notice of Settlement Plaintiff's Ninth Notice of Settlement of an Avoidance Action Pursuant to Settlement Procedures Order Filed by CR Holding Liquidating, Inc. (Attachments: # 1 Exhibit A) (Griffiths, Norman) (Entered: 05/12/2021)

Document posted on May 11, 2021 in the bankruptcy, 3 pages and 0 tables.

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(the “Debtors” or “Plaintiff”) by and through its attorneys, hereby files this Ninth Notice of Settlement of An Avoidance Action Pursuant to Settlement Procedures Order (the “Notice”) pursuant to the Order on Motion for Authority to Settle Classes of Preference Claim Controversies Pursuant to Bankruptcy Rule 9019(b)Pursuant to the Settlement Procedures Order, Avoidance Actions with gross amounts demanded greater than or equal to $75,000.00 but less than $250,000.00, are subject to Notice of Settlement Procedures.Under the Notice of Settlement Procedures, the Plaintiff may file notices of settlement subject to notice and a ten (10) day objection period.CR Holding Liquidating Inc. (f/k/a Charlotte Russe Holding Inc.) (4325); CR Holdings Liquidating Corporation (f/k/a Charlotte Russe Holdings Corporation) (1045); CR Intermediate Liquidating Corporation (f/k/a Charlotte Russe Intermediate Corporation) (6345); CR Enterprise Liquidating, Inc. (f/k/a Charlotte Russe Enterprise, Inc.) (2527); CR Liquidating, Inc. (f/k/a Charlotte Russe, Inc.) (0505); CR Merchandising Liquidating, Inc. (f/k/a Charlotte Russe Merchandising, Inc.) (9453); and CR Administration Liquidating, Inc. (f/k/a Charlotte Russe Administration, Inc.) (9456).The Plaintiff has negotiated settlement of a certain Avoidance Action identified on Exhibit A attached hereto.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 CR Holding Liquidating, Inc., et al.,1 Case No.: 19-10210 (LSS) (Jointly Administered) Debtors. PLAINTIFF’S NINTH NOTICE OF SETTLEMENT OF AN AVOIDANCE ACTION PURSUANT TO SETTLEMENT PROCEDURES ORDER CR Holding Liquidating, Inc., et. al. (the “Debtors” or “Plaintiff”) by and through its attorneys, hereby files this Ninth Notice of Settlement of An Avoidance Action Pursuant to Settlement Procedures Order (the “Notice”) pursuant to the Order on Motion for Authority to Settle Classes of Preference Claim Controversies Pursuant to Bankruptcy Rule 9019(b) (the “Settlement Procedures Order”) entered on August 28, 2019 and avers as follows: 1. Commencing on or about October 18, 2019 Plaintiff filed adversary proceedings against certain defendants for the avoidance and recovery of certain transfers pursuant to sections 547, 548, 549 and 550 of title 11 of the United States Code (the “Avoidance Actions”). 2. Pursuant to the Settlement Procedures Order, Avoidance Actions with gross amounts demanded greater than or equal to $75,000.00 but less than $250,000.00, are subject to Notice of Settlement Procedures. Under the Notice of Settlement Procedures, the Plaintiff may file notices of settlement subject to notice and a ten (10) day objection period. Pursuant to the Settlement Procedures Order, the notice of electronic filing issued through the Court’s Electronic Filing System shall constitute adequate and sufficient service of the Notice of Settlement. 1 The Debtors and the last four digits of their respective federal taxpayer identification numbers are as follows: CR Holding Liquidating Inc. (f/k/a Charlotte Russe Holding Inc.) (4325); CR Holdings Liquidating Corporation (f/k/a Charlotte Russe Holdings Corporation) (1045); CR Intermediate Liquidating Corporation (f/k/a Charlotte Russe Intermediate Corporation) (6345); CR Enterprise Liquidating, Inc. (f/k/a Charlotte Russe Enterprise, Inc.) (2527); CR Liquidating, Inc. (f/k/a Charlotte Russe, Inc.) (0505); CR Merchandising Liquidating, Inc. (f/k/a Charlotte Russe Merchandising, Inc.) (9453); and CR Administration Liquidating, Inc. (f/k/a Charlotte Russe Administration, Inc.) (9456). The Debtors’ mailing address is 3111 Camino Del Rio N. Suite 400, San Diego, CA 92108.

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3. The Plaintiff has negotiated settlement of a certain Avoidance Action identified on Exhibit A attached hereto. Exhibit A contains the name of the defendant (the “Defendant,”) the total transfers sought against the Defendant, the amount paid or to be paid by the Defendant to Plaintiff in settlement of the Avoidance Action (the “Proposed Settlement”). 4. For the Proposed Settlement identified on Exhibit A, Plaintiff believes that the Proposed Settlement is in the best interest of the creditors taking into account the efficacy of the defenses raised by the Defendant. Additionally, given the known cost of further pursuing the matter, Plaintiff has determined that the net result to creditors would be greater through the Proposed Settlement than through further litigation. 5. Notice of the Proposed Settlement has been provided as required in the Settlement Procedures Order. 6. Absent any objections on or before May 24, 2021, the settlement listed on Exhibit A shall be deemed approved without any further action of the Plaintiff or Court. Dated: May 12, 2021 CONNOLLY GALLAGHER LLP By: /s/ N. Christopher Griffiths_________ N. Christopher Griffiths (#5180) Stephanie S. Riley (#5803) 1201 North Market Street, 20th Floor Wilmington, DE 19801 Telephone: 302-888-6313 Email: cgriffiths@connollygallagher.com -and- ASK LLP Joseph L. Steinfeld, Jr., Esq. 2600 Eagan Woods Drive, Suite 400 St. Paul, MN 55121 Telephone: (651) 406-9665 e-mail: jsteinfeld@askllp.com -and- 2

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Marianna Udem, Esq. Edward E. Neiger, Esq. 151 West 46th Street, 4th Fl. New York, NY 10036 Telephone: (212) 267-7342 E-mail: mudem@askllp.com Counsel for CR Holding Liquidating, Inc., et. al. . 3

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