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Full title: Certification of Counsel Regarding Reorganized Debtor's Third Omnibus Objection (Non-Substantive) to Certain No Liability Claims with No Documentation Pursuant to Section 502 of the Bankruptcy Code and Rule 3007 of the Federal Rules of Bankruptcy Procedure (related document(s)409) Filed by FIC Restaurants, Inc.. (Attachments: # 1 Exhibit A (Proposed Order)) (Johnson, Ericka) (Entered: 08/16/2021)

Document posted on Aug 15, 2021 in the bankruptcy, 2 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

On June 30, 2021, the Reorganized Debtor filed the Reorganized Debtor’s Third Omnibus Objection (Non-Substantive) to Certain No Liability Claims with No Documentation Pursuant to Section 502 of the Bankruptcy Code and Rule 3007 of the Federal Rules of Bankruptcy ProcedurePursuant 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).Ms. Yambot subsequently informed the 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)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).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.

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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.: 409 ) Hearing Date: August 17, 2021 at 11:00 a.m. (ET) CERTIFICATION OF COUNSEL REGARDING REORGANIZED DEBTOR’S THIRD OMNIBUS OBJECTION (NON-SUBSTANTIVE) TO CERTAIN NO LIABILITY CLAIMS WITH NO DOCUMENTATION 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 Third Omnibus Objection (Non-Substantive) to Certain No Liability Claims with No Documentation Pursuant to Section 502 of the Bankruptcy Code and Rule 3007 of the Federal Rules of Bankruptcy Procedure [Docket No. 409] (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. On July 20, 2021, Leonidez C. Yambot (Claim No. 64) filed a response [Docket No. 422] (the “Response”) to the Omnibus Objection. Ms. Yambot subsequently informed the 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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undersigned counsel to the Reorganized Debtor that her Response is resolved and that she does not object to the disallowance of her claim in the bankruptcy cases. 3. 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 other answer, objection, or other responsive pleading to the Omnibus Objection has been filed. 4. Accordingly, the undersigned counsel to the Reorganized Debtor respectfully submits that the proposed form of order attached hereto as Exhibit A (which is identical to the proposed order attached to the Omnibus Objection) may be entered by the Court without further notice or hearing. Dated: August 16, 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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