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Full title: Certification of Counsel Regarding Reorganized Debtor's Second Omnibus Objection (Substantive) to Certain No Liability and Overstated Claims Pursuant to Section 502 of the Bankruptcy Code and Rule 3007 of the Federal Rules of Bankruptcy Procedure (related document(s)407) Filed by FIC Restaurants, Inc.. (Attachments: # 1 Exhibit A (Revised Proposed Order) # 2 Exhibit B (Redline)) (Johnson, Ericka) (Entered: 08/12/2021)

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

Bankrupt11 Summary (Automatically Generated)

On June 30, 2021, the Reorganized Debtor filed the Reorganized Debtor’s Second Omnibus Objection (Substantive) to Certain No Liability and Overstated Claims Pursuant to Section 502 of the Bankruptcy Code and Rule 3007 of the Federal Rules of Bankruptcy ProcedureHere are their jurisdictions of organization and the last four digits of their U.S. taxpayer identification numbers: (1) FIC Holdings, LLC, a Delaware limited liability company (0204); (2) Neapolitan Group Holdings, LLC, a Delaware limited liability company (7922); (3) Friendly’s Restaurants, LLC, a Delaware limited liability company (0696); and (4) Friendly’s Franchising, LLC, a Delaware limited liability company (4364). 221), (ii) Wilton Mall LLC (Claim No. 38), (iii) Ohio Edison (Claim No. 10) and (iv) G&I IX Empire McKinley Milestrip LLC (Claim Nos.The Reorganized Debtor and G&I IX Empire McKinley Milestrip LLC have agreed to an extended response deadline and to adjourn the Omnibus Objection to the omnibus hearing on September 29, 2021 at 11:00 a.m. with respect to Claim Nos. 160 and 161.The Reorganized Debtor has revised Exhibits 1 and 2 to the proposed order sustaining the Omnibus Objection consistent with paragraphs 3 through 5 above.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) In re: ) Chapter 11 ) FIC RESTAURANTS, INC.,1 ) Case No. 20-12807 (CSS) ) Reorganized Debtor. ) Related Docket No.: 407 ) Hearing Date: August 17, 2021 at 11:00 a.m. (ET) CERTIFICATION OF COUNSEL REGARDING REORGANIZED DEBTOR’S SECOND OMNIBUS OBJECTION (SUBSTANTIVE) TO CERTAIN NO LIABILITY AND OVERSTATED CLAIMS PURSUANT TO SECTION 502 OF THE BANKRUPTCY CODE AND RULE 3007 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURE The undersigned counsel to FIC Restaurants, Inc. (the “Reorganized Debtor”) hereby certifies as follows: 1. On June 30, 2021, the Reorganized Debtor filed the Reorganized Debtor’s Second Omnibus Objection (Substantive) to Certain No Liability and Overstated Claims Pursuant to Section 502 of the Bankruptcy Code and Rule 3007 of the Federal Rules of Bankruptcy Procedure [Docket No. 407] (the “Omnibus Objection”). Pursuant to the notice attached to the Omnibus Objection, responses or objections to the Omnibus Objection were due on or before July 30, 2021 at 4:00 p.m. (prevailing Eastern Time). A hearing on the Omnibus Objection is scheduled for August 17, 2021 at 11:00 a.m. (prevailing Eastern Time). 2. Counsel to the Reorganized Debtor received informal inquiries or responses regarding the Omnibus Objection from the following claimants: (i) National Grid (Claim No. 1 The Reorganized Debtor in this chapter 11 case, its jurisdiction of organization, and the last four digits of its U.S. taxpayer identification number is FIC Restaurants, Inc., a Massachusetts, corporation (1388) (“FIC”). Prior to the closure of their bankruptcy cases, the following Debtors were jointly administered with the FIC chapter 11 case. Here are their jurisdictions of organization and the last four digits of their U.S. taxpayer identification numbers: (1) FIC Holdings, LLC, a Delaware limited liability company (0204); (2) Neapolitan Group Holdings, LLC, a Delaware limited liability company (7922); (3) Friendly’s Restaurants, LLC, a Delaware limited liability company (0696); and (4) Friendly’s Franchising, LLC, a Delaware limited liability company (4364). The Reorganized Debtor’s mailing address is 40 Post Office Park, P.O. Box 1087, Wilbraham, MA 01095-1087.

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221), (ii) Wilton Mall LLC (Claim No. 38), (iii) Ohio Edison (Claim No. 10) and (iv) G&I IX Empire McKinley Milestrip LLC (Claim Nos. 160 and 161). 3. On August 11, 2021, the Reorganized Debtor filed a notice of withdrawal of the Omnibus Objection solely with respect to Claim No. 221 of National Grid. See Docket No. 433. 4. With respect to Claim No. 38 of Wilton Mall LLC, the Reorganized Debtor and Wilton Mall LLC have agreed to a modified, reduced claim in the amount of $161,580.01. 5. The Reorganized Debtor and G&I IX Empire McKinley Milestrip LLC have agreed to an extended response deadline and to adjourn the Omnibus Objection to the omnibus hearing on September 29, 2021 at 11:00 a.m. with respect to Claim Nos. 160 and 161. 6. With respect to the informal inquiry from Ohio Edison (Claim No. 10), the Reorganized Debtor has provided documentation to Ohio Edison in further support of the Omnibus Objection. As of the date hereof, Ohio Edison has not further responded, either formally or informally, to the Omnibus Objection. 7. Except as set forth herein, counsel to the Reorganized Debtor has not received any other formal or informal answer, objection, or other response to the relief requested pursuant to the Omnibus Objection. The undersigned further certifies that the Court’s docket in these cases reflects that no answer, objection, or other responsive pleading to the Omnibus Objection has been filed. 8. The Reorganized Debtor has revised Exhibits 1 and 2 to the proposed order sustaining the Omnibus Objection consistent with paragraphs 3 through 5 above. The proposed order attaching the revised exhibits is attached hereto as Exhibit A (including exhibits thereto, the “Revised Proposed Order”). Attached hereto as Exhibit B is a redline reflecting the changes to the proposed order attached to the Omnibus Objection and the Revised Proposed Order.

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9. Accordingly, the undersigned counsel to the Reorganized Debtor respectfully submits that the Revised Proposed Order attached hereto as Exhibit A may be entered by the Court without further notice or hearing. Dated: August 12, 2021 WOMBLE BOND DICKINSON (US) LLP Wilmington, Delaware /s/ Ericka F. Johnson Matthew P. Ward (DE Bar No. 4471) Ericka F. Johnson (DE Bar No. 5024) 1313 North Market Street, Suite 1200 Wilmington, Delaware 19801 Telephone: (302) 252-4320 Facsimile: (302) 252-4330 Email: matthew.ward@wbd-us.com Email: ericka.johnson@wbd-us.com Counsel to the Reorganized Debtor

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