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Full title: Certification of Counsel Regarding Stipulation and Agreed Order Regarding Allowance of Administrative Expense Claim of Realplay Corp., Inc. (related document(s)588) Filed by CR Holding Liquidating, Inc.. (Attachments: # 1 Exhibit A (Proposed Order)) (Flasser, Gregory) (Entered: 07/12/2021)

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

Bankrupt11 Summary (Automatically Generated)

Proofs of Claim by Governmental Units, (III) Establishing an Amended Schedules Bar Date, (IV) Establishing a Rejection Damages Bar Date, (V) Approving the Form and Manner for Filing Proofs of Claim, (VI) Approving the Proposed Notice of Bar Dates, and (VII)Pursuant to the Bar Date Order and related notice [D.I. 549], the 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).Prior to the General Bar Date, on May 2, 2019, Realplay Corp., Inc. (“Realplay”) filed a proof of claim, designated by the claims agent as Claim No.The Realplay Proof of Claim includes, but is not limited to, an administrative expense claim in the amount of $318,208.80 (the “Administrative Expense Claim”) for the value of goods delivered by Realplay and received by the Debtors within twenty (20) days prior to the Petition Date, pursuant to section 503(b)(9) of the Bankruptcy Code.Regarding Allowance of Administrative Expense Claim of Realplay Corp., Inc. (the “Stipulation”), a true and correct copy of which is attached as Exhibit 1 to the proposed form of order approving the Stipulation, which order is attached hereto as Exhibit A. WHEREFORE, the Debtors respectfully request that the Court enter the Proposed Order at the Court’s earliest convenience.

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UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE Chapter 11 In re Case No.: 19-10210 (LSS) CR Holding Liquidating, Inc., et al.,1 (Jointly Administered) Debtors. CERTIFICATION OF COUNSEL REGARDING STIPULATION AND AGREED ORDER REGARDING ALLOWANCE OF ADMINISTRATIVE EXPENSE CLAIM OF REALPLAY CORP., INC. I, Gregory J. Flasser, co-counsel to the above-captioned debtors and debtors-in-possession (collectively, the “Debtors”) in the above captioned chapter 11 cases, hereby certify and state as follows: 1. On February 3, 2019 (the “Petition Date”), the Debtors filed petitions for relief under chapter 11 of Title 11 of the United States Code (the “Bankruptcy Code”) in the United States Bankruptcy Court for the District of Delaware (the “Court”). 2. On April 24, 2019, the Court entered the Order (I) Establishing a General Bar Date to File Proofs of Claim, (II) Establishing a Bar Date to File Proofs of Claim by Governmental Units, (III) Establishing an Amended Schedules Bar Date, (IV) Establishing a Rejection Damages Bar Date, (V) Approving the Form and Manner for Filing Proofs of Claim, (VI) Approving the Proposed Notice of Bar Dates, and (VII) Granting Related Relief [D.I. 532] (the “Bar Date Order”). Pursuant to the Bar Date Order and related notice [D.I. 549], the 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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deadline for all persons and entities to file proofs of claim, including claims asserted pursuant to section 503(b)(9) of the Bankruptcy Code, was established as May 30, 2019 (the “General Bar Date”). 3. Prior to the General Bar Date, on May 2, 2019, Realplay Corp., Inc. (“Realplay”) filed a proof of claim, designated by the claims agent as Claim No. 517 (the “Realplay Proof of Claim”). The Realplay Proof of Claim includes, but is not limited to, an administrative expense claim in the amount of $318,208.80 (the “Administrative Expense Claim”) for the value of goods delivered by Realplay and received by the Debtors within twenty (20) days prior to the Petition Date, pursuant to section 503(b)(9) of the Bankruptcy Code. 4. On May 17, 2019, Realplay filed the Motion of Realplay Corp., Inc. for Allowance and Payment of Administrative Expenses Under 11 U.S.C. § 503(b)(9) [D.I. 588] (the “Administrative Expense Motion”) seeking allowance of the Administrative Expense Claim and an order requiring the Debtors to immediately or as soon thereafter as practicable, pay the same. 5. Following discussions between counsel for the Debtors and Realplay, the issues raised by the Administrative Expense Motion and Administrative Expense Claim have been resolved, subject to approval by the Court, as set forth in the Stipulation and Agreed Order Regarding Allowance of Administrative Expense Claim of Realplay Corp., Inc. (the “Stipulation”), a true and correct copy of which is attached as Exhibit 1 to the proposed form of order approving the Stipulation, which order is attached hereto as Exhibit A.

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WHEREFORE, the Debtors respectfully request that the Court enter the Proposed Order at the Court’s earliest convenience. Dated: July 12, 2021 Wilmington, Delaware BAYARD, P.A. /s/ Gregory J. Flasser Erin R. Fay (No. 5268) Daniel N. Brogan (No. 5723) Gregory J. Flasser (No. 6154) 600 North King Street, Suite 400 Wilmington, Delaware 19801 Telephone: (302) 655-5000 Facsimile: (302) 658-6395 Email: efay@bayardlaw.com dbrogan@bayardlaw.com gflasser@bayardlaw.com - and - COOLEY LLP Cathy Hershcopf Michael Klein Summer M. McKee 55 Hudson Yards New York, New York 10001 Telephone: (212) 479-6000 Facsimile: (212) 479-6275 Email: chershcopf@cooley.com mklein@cooley.com smckee@cooley.com Co-Counsel for the Debtors and Debtors-in- Possession

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