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Full title: Certification of Counsel Regarding Debtor's Fourth Omnibus Objection (Substantive) to Certain Claims Pursuant to 11 U.S.C. § 502, Fed. R. Bankr. P. 3007-1 (Disallow; Reduce and Allow; Reclassify) (related document(s)792) Filed by Klausner Lumber One LLC. (Attachments: # 1 Exhibit A # 2 Exhibit B) (Amer, Nader) (Entered: 04/14/2021)

Document posted on Apr 13, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Debtor filed the Debtor’s Reply in Support of Its Fourth Omnibus Objection (Substantive) to Claim Number 50 Filed by Genesis Timber LLC (D.I. 838).After careful review of the informal responses and the Debtor’s books and records, the Debtor has withdrawn its objections as to the Strategic Claim and the Rigoni Claim.the relief requested in the Omnibus Objection (the “Original Order”) to remove the Genesis Claim, which is being adjourned, and the Strategic Claim and Rigoni Claim, as to which the Debtor is withdrawing its Omnibus Objection.For the convenience of the Court and all parties in interest, a blackline comparing the Revised Order against the form of order attached to the Omnibus Objection is attached hereto as Exhibit B. Dated: April 14, 2021 MORRIS, NICHOLS, ARSHT & TUNNELL LLP Wilmington, Delaware /s/

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE Chapter 11 In re Case No. 20-11033 (KBO) KLAUSNER LUMBER ONE LLC, Debtor.1 Re: D.I. 792 CERTIFICATION OF COUNSEL REGARDING DEBTOR’S FOURTH OMNIBUS OBJECTION (SUBSTANTIVE) TO CERTAIN CLAIMS PURSUANT TO 11 U.S.C. § 502, FED. R. BANKR. P. 3007 AND DEL. L.R. 3007-1 (DISALLOW; REDUCE AND ALLOW; RECLASSIFY) The undersigned counsel to the above-captioned debtor and debtor in possession (the “Debtor”) hereby certifies as follows: 1. On March 16, 2021, the Debtor filed the Debtor’s Fourth Omnibus Objection (Substantive) to Certain Claims Pursuant to 11 U.S.C. § 502, Fed. R. Bankr. P. 3007-1 (Disallow; Reduce and Allow; Reclassify) [D.I. 792] (the “Omnibus Objection”). 2. Pursuant to the notice of the Omnibus Objection, objections or responses to the relief requested in the Omnibus Objection were to be filed and served no later than March 30, 2021 at 4:00 pm. (ET) (the “Response Deadline”). 3. Before the Response Deadline passed, Genesis Timber LLC (“Genesis”) filed its Objection to Debtors’ Fourth Omnibus Objection (Substantive) to Certain Claims Pursuant to 11 U.S.C. § 502, Fed. R. Bankr. P. 3007 and Del. L.R. 3007-1 (Disallow; Reduce and Allow; Reclassify) [D.I. 823] (the “Genesis Response”) concerning its claim no. 50 (the “Genesis Claim”). After careful review of the Genesis Objection and the Debtor’s books and records, the 1 The last four digits of the Debtor's federal tax identification number are 9109. The Debtor’s mailing address is Klausner Lumber One LLC, P.O. Box 878 Middleburg, VA 20118.

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Debtor filed the Debtor’s Reply in Support of Its Fourth Omnibus Objection (Substantive) to Claim Number 50 Filed by Genesis Timber LLC (D.I. 838). Genesis and the Debtor have agreed to adjourn the hearing on the Genesis Claim to the hearing currently scheduled for April 29, 2021, at 10:00 a.m. (ET). 4. Additionally, before the Response Deadline passed, Strategic Systems, Inc. (“Strategic”) and M.A. Rigoni Inc. (“Rigoni”) provided the Debtor their informal responses to the relief requested in the Omnibus Objection regarding their claims numbered 148 (the “Strategic Claim”) and 151 (the “Rigoni Claim”), respectively. After careful review of the informal responses and the Debtor’s books and records, the Debtor has withdrawn its objections as to the Strategic Claim and the Rigoni Claim. 5. The Debtor has revised the original form of order granting the relief requested in the Omnibus Objection (the “Original Order”) to remove the Genesis Claim, which is being adjourned, and the Strategic Claim and Rigoni Claim, as to which the Debtor is withdrawing its Omnibus Objection. 6. The Revised Order is attached hereto as Exhibit A. For the convenience of the Court and all parties in interest, a blackline comparing the Revised Order against the form of order attached to the Omnibus Objection is attached hereto as Exhibit B. WHEREFORE, the Debtor respectfully requests that the Court enter the Revised Order substantially in the form attached hereto as Exhibit A at its earliest convenience.

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Dated: April 14, 2021 MORRIS, NICHOLS, ARSHT & TUNNELL LLP Wilmington, Delaware /s/Nader A. Amer Robert J. Dehney (No. 3578) Eric D. Schwartz (No. 3134) Daniel B. Butz (Bar No. 4227) Nader A. Amer (Bar No. 6635) 1201 North 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 M. Ladd (admitted pro hac vice) 1201 RXR Plaza Uniondale, NY 11556 Tel: 516-622-9200 tdraghi@westermanllp.com aladd@westermanllp.com Counsel for Debtor and Debtor in Possession

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