HTML Document View

Full title: Certificate of No Objection Regarding Debtors Third Motion for Entry of an Order (I) Extending the Debtors Time to File Notices of Removal of Claims and Causes of Action Related to the Debtors Chapter 11 Case and (II) Granting Related Relief (related document(s)770) Filed by Klausner Lumber Two LLC. (Amer, Nader) (Entered: 06/14/2021)

Document posted on Jun 13, 2021 in the bankruptcy, 2 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

LLC, Case No. 20-11518-KBO Debtor.1 Re: D.I. 770 CERTIFICATE OF NO OBJECTION REGARDING DEBTOR’S THIRD MOTION FOR ENTRY OF AN ORDER (I) EXTENDING THE DEBTOR’S TIME TO FILE NOTICES OF REMOVAL OF CLAIMS AND CAUSES OF ACTION RELATED TO THE DEBTOR’S CHAPTER 11 CASE AND (II) GRANTING RELIEF The undersigned hereby certifies that, as of the date hereof, Morris, Nichols, Arsht & Tunnell LLP (“Morris Nichols”) has received no answer, objection, comments, or other responsive pleading to the Debtor’s Third Motion for Entry of an Order (I) Extending the Debtor’s Time to File Notices of Removal of Claims and Causes of Action Related to the Debtor’s Chapter 11 Case and (II)The undersigned further certifies that Morris Nichols has reviewed the Court’s docket in these cases and that no answer, objection, comments, or other responsive pleading to the Motion appears thereon.Pursuant to the notice of hearing regarding the Motion, objections to the Motion were to be filed and served no later than May 27, 2021, at 4:00 p.m. (EDT).Alison Ladd (admitted pro hac vice) 1201 RXR Plaza Uniondale, New York 11556

List of Tables

Document Contents

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re Chapter 11 Klausner Lumber Two LLC, Case No. 20-11518-KBO Debtor.1 Re: D.I. 770 CERTIFICATE OF NO OBJECTION REGARDING DEBTOR’S THIRD MOTION FOR ENTRY OF AN ORDER (I) EXTENDING THE DEBTOR’S TIME TO FILE NOTICES OF REMOVAL OF CLAIMS AND CAUSES OF ACTION RELATED TO THE DEBTOR’S CHAPTER 11 CASE AND (II) GRANTING RELIEF The undersigned hereby certifies that, as of the date hereof, Morris, Nichols, Arsht & Tunnell LLP (“Morris Nichols”) has received no answer, objection, comments, or other responsive pleading to the Debtor’s Third Motion for Entry of an Order (I) Extending the Debtor’s Time to File Notices of Removal of Claims and Causes of Action Related to the Debtor’s Chapter 11 Case and (II) Granting Related Relief [D.I. 770] (the “Motion”), filed on May 13, 2021. The undersigned further certifies that Morris Nichols has reviewed the Court’s docket in these cases and that no answer, objection, comments, or other responsive pleading to the Motion appears thereon. Pursuant to the notice of hearing regarding the Motion, objections to the Motion were to be filed and served no later than May 27, 2021, at 4:00 p.m. (EDT). WHEREFORE, Klausner Lumber Two LLC (“Klausner”) respectfully requests that the Court enter the order attached to the Motion at its earliest convenience. 1 The last four digits of the Debtor’s EIN is 4897. The Debtor’s mailing address is P.O. Box C, Redding Ridge CT, 06876.

1

Dated: June 14, 2021 MORRIS, NICHOLS, ARSHT & TUNNELL LLP Wilmington, Delaware /s/Nader A. Amer Robert J. Dehney (No. 3578) Eric Schwartz (No. 3134) Daniel B. Butz (No. 4227) Nader A. Amer (No. 6635) 1201 N. Market Street, 16th Floor P.O. Box 1347 Wilmington, Delaware 19899-1347 Telephone: (302) 658-9200 Facsimile: (302) 658-3989 Email: dbutz@mnat.com namer@mnat.com and WESTERMAN BALL EDERER MILLER ZUCKER & SHARFSTEIN, LLP Thomas A. Draghi (admitted pro hac vice) Alison Ladd (admitted pro hac vice) 1201 RXR Plaza Uniondale, New York 11556 Telephone: (516) 622-9200 Facsimile: (516) 622-9212 Email: tdraghi@westermanllp.com aladd@westermanllp.com Co-counsel to Klausner Lumber Two LLC

2