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Full title: Omnibus Objection to Claims First Omnibus Objection (Non-Substantive) of the Reorganized Debtor to Claims Pursuant to Sections 105 and 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007 and Local Rule 3007-1. Filed by MUJI U.S.A. Limited. Hearing scheduled for 7/7/2021 at 10:30 AM at US Bankruptcy Court, 824 Market St., 5th Fl., Courtroom #4, Wilmington, Delaware. Objections due by 6/18/2021. (Attachments: # 1 Exhibit A - Proposed Order # 2 Declaration # 3 Notice) (Meloro, Dennis) (Entered: 05/28/2021)

Document posted on May 27, 2021 in the bankruptcy, 7 pages and 0 tables.

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Exhibit A to the attached order (collectively, the “Late-Filed Claims” and the order, the “Proposed Order”) that were filed after the applicable Claims Bar Dates (as defined below), and files this first omnibus, non-substantive objection (the “First Omnibus Objection”) to such Late-Filed Claims pursuant to sections 105 and 502(b) of title 11 of the United States Code, 11 U.S.C. §§ 101, et seq.(the “Bankruptcy Code”), Rule 3007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 3007-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), seeking entry of an order, substantially in the form of the Proposed Order, disallowing each of the Late-Filed Claims set forth in Exhibit A to the Proposed Order.See Notice of: (I) Entry of Order Confirming Amended Chapter 11 Plan of Reorganization of MUJI U.S.A. Limited Pursuant to Chapter 11 of the Bankruptcy Code (as Modified);(the “Bar Date Order”), which, among other things, established: (a) September 22, 2020, at 5:00 p.m. (prevailing Eastern Time) as the deadline for all non-governmental entities holding or wishing to assert a “claim” (as defined in section 101(5) of the Bankruptcy Code) against the Debtor that arose before the Petition Date to file a proof of such claim in writing (the “General Bar Date”) and (b) January 6, 2021, at 5:00 p.m. (prevailing Eastern Time) as the deadline for all governmental entities holding or wishing to assert a “claim” (as defined in section 101(5) of the Bankruptcy Code) against the Debtor that arose before the Petition Date to file a proof of such claim in writing (the “Governmental Bar Date”).First Omnibus Objection, and for the reasons stated herein, the Reorganized Debtor seeks entry of an order, substantially in the form of the Proposed Order, pursuant to sections 105 and 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1, disallowing each of the Late-Filed Claims as set forth in Exhibit A to the Proposed Order.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 MUJI U.S.A. LIMITED,1 Case No. 20-11805 (MFW) Reorganized Debtor. Objection Deadline: June 18, 2021 at 4:00 p.m. (ET) Hearing Date: July 7, 2021 at 10:30 a.m. (ET) FIRST OMNIBUS OBJECTION (NON-SUBSTANTIVE) OF THE REORGANIZED DEBTOR TO CLAIMS PURSUANT TO SECTIONS 105 AND 502(b) OF THE BANKRUPTCY CODE, BANKRUPTCY RULE 3007 AND LOCAL RULE 3007-1 LATE-FILED CLAIMS **** CLAIMANTS RECEIVING THIS OBJECTION SHOULD LOCATE THEIR NAME(S) AND CLAIM NUMBER(S) IN EXHIBIT A TO THE ATTACHED PROPOSED ORDER, WHICH CONTAIN THE GROUNDS FOR OBJECTIONS PERTAINING TO THEIR CLAIM(S) AND THE RELIEF BEING SOUGHT BY THE REORGANIZED DEBTOR. YOUR SUBSTANTIVE RIGHTS MAY BE AFFECTED BY THIS OBJECTION AND BY ANY FURTHER OBJECTION THAT MAY BE FILED BY THE REORGANIZED DEBTOR. THE RELIEF SOUGHT HEREIN IS WITHOUT PREJUDICE TO THE REORGANIZED DEBTOR’S RIGHTS TO PURSUE FURTHER SUBSTANTIVE OR NON-SUBSTANTIVE OBJECTIONS AGAINST THE CLAIMS LISTED IN EXHIBIT A TO THE ATTACHED PROPOSED ORDER. **** 1 The last four digits of the Reorganized Debtor’s federal tax identification number are 2229. The location of the Reorganized Debtor’s principal place of business is 250 West 39th Street, Suite 202, New York, NY 10018.

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MUJI U.S.A. Limited, the above-captioned reorganized debtor (the “Reorganized Debtor,” and prior to the effective date of the confirmed Plan (as defined below), the “Debtor”), hereby objects to those claims listed in Exhibit A to the attached order (collectively, the “Late-Filed Claims” and the order, the “Proposed Order”) that were filed after the applicable Claims Bar Dates (as defined below), and files this first omnibus, non-substantive objection (the “First Omnibus Objection”) to such Late-Filed Claims pursuant to sections 105 and 502(b) of title 11 of the United States Code, 11 U.S.C. §§ 101, et seq. (the “Bankruptcy Code”), Rule 3007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 3007-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), seeking entry of an order, substantially in the form of the Proposed Order, disallowing each of the Late-Filed Claims set forth in Exhibit A to the Proposed Order. In support of this First Omnibus Objection, the Reorganized Debtor respectfully states as follows: Jurisdiction, Venue and Statutory Predicates 1. The Court has jurisdiction over this First Omnibus Objection pursuant to 28 U.S.C. §§ 157 and 1334 and Article X of the Plan. Venue is proper in this district pursuant to 28 U.S.C. §§ 1408 and 1409. This matter is core within the meaning of 28 U.S.C. § 157(b)(2). Under Rule 9013-1(f) of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware, the Reorganized Debtor consents to entry of a final order under Article III of the United States Constitution. 2. The statutory predicates for the relief sought herein are sections 105 and 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1.

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Relevant Background A. Chapter 11 Case 3. On July 10, 2020 (the “Petition Date”), the Debtor filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code in this Court. A detailed description of the facts and circumstances leading to this chapter 11 case is set forth in the Declaration of John Bittner in Support of the Debtor’s Chapter 11 Petition and Requests for First Day Relief [Docket No. 13]. 4. No committee of unsecured creditors was appointed in this chapter 11 case. B. Confirmation of the Debtor’s Plan 5. On December 21, 2020, the Court entered an order [Docket No. 277] (the “Confirmation Order”) confirming the Amended Chapter 11 Plan of Reorganization of MUJI U.S.A. Limited Pursuant to Chapter 11 of the Bankruptcy Code (as Modified) (the “Plan”) [Docket No. 277-1]. 6. The Effective Date (as defined in the Plan) occurred on December 31, 2020. See Notice of: (I) Entry of Order Confirming Amended Chapter 11 Plan of Reorganization of MUJI U.S.A. Limited Pursuant to Chapter 11 of the Bankruptcy Code (as Modified); (II) Occurrence of Effective Date; and (III) Bar Date Notice for Rejection Damages, Administrative Claims, and Professional Fee Claims [Docket No. 286]. C. Schedules and Claims Bar Date 7. On August 14, 2020, the Debtor filed its Schedules of Assets and Liabilities for MUJI U.S.A. Limited [Docket No. 110] (as may be amended, the “Schedules”). 8. On August 19, 2020, the Court entered the Order (I) Fixing Deadlines for Filing Proofs of Claim and (II) Approving the Form and Manner of Notice Thereof [Docket No. 122]

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(the “Bar Date Order”), which, among other things, established: (a) September 22, 2020, at 5:00 p.m. (prevailing Eastern Time) as the deadline for all non-governmental entities holding or wishing to assert a “claim” (as defined in section 101(5) of the Bankruptcy Code) against the Debtor that arose before the Petition Date to file a proof of such claim in writing (the “General Bar Date”) and (b) January 6, 2021, at 5:00 p.m. (prevailing Eastern Time) as the deadline for all governmental entities holding or wishing to assert a “claim” (as defined in section 101(5) of the Bankruptcy Code) against the Debtor that arose before the Petition Date to file a proof of such claim in writing (the “Governmental Bar Date”). 9. Furthermore, pursuant to the Confirmation Order and Plan, holders of Administrative Claims (as defined in the Plan) were required to file requests for payment of Administrative Claims and serve such requests on the Notice Parties (as defined in the Plan), no later than which is thirty (30) days after the Effective Date. Accordingly, the Administrative Claims Bar Date was February 1, 2021 (the Administrative Claims Bar Date, together with the General Bar Date and Governmental Bar Date, the “Claims Bar Dates”). 10. Notice of the Claims Bar Dates was provided by mail in accordance with the procedures outlined in the Bar Date Order and the Confirmation Order, as applicable. See Docket Nos. 138, 290. D. Claims Reconciliation Process 11. To date, entities have filed approximately eighty-four (84) proofs of claims against the Debtor’s estate on an aggregate basis (together with all other claims on the Debtor’s Schedules, the “Claims”). The Reorganized Debtor and its advisors (collectively, the “Reviewing Parties”) have been working diligently to review the claims for which a proof of claim has been filed, including any supporting documentation filed therewith. For the reasons set forth below, and

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based on its review to date, the Reorganized Debtor has determined that the Late-Filed Claims should be disallowed as set forth herein. Relief Requested 12. By this First Omnibus Objection, and for the reasons stated herein, the Reorganized Debtor seeks entry of an order, substantially in the form of the Proposed Order, pursuant to sections 105 and 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1, disallowing each of the Late-Filed Claims as set forth in Exhibit A to the Proposed Order. Basis for Relief 13. The Reviewing Parties have reviewed each of the Late-Filed Claims identified in Exhibit A and determined that each was filed after the applicable Claims Bar Date. Indeed, each Late-Filed Claim failed to comply with the terms of the Bar Date Order or Confirmation Order (as applicable). The Bar Date Order was served on all potential claimants and further notice of the Claims Bar Dates was provided through the procedures set forth in the Bar Date Order and Confirmation Order (as applicable). All claimants, including those that submitted the Late-Filed Claims listed in Exhibit A to the Proposed Order, were therefore notified of the date by which a proof of claim against the Debtor was required to be filed and the consequences of the failure to file a proof of claim timely. 14. Failure to disallow the Late-Filed Claims could result in the purported claimants receiving a greater distribution than that to which they are entitled to the detriment of other similarly-situated creditors that timely filed a proof of claim. For the avoidance of doubt, this First Omnibus Objection does not affect the amount, priority or classification of any claim that appears on the Debtor’s Schedules (as applicable). Accordingly, the Reorganized Debtor

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respectfully requests that each Late-Filed Claim in Exhibit A attached hereto be disallowed in its entirety. Reservation of Rights 15. The Reorganized Debtor expressly reserves the right to amend, modify or supplement this First Omnibus Objection and to file additional objections to the Late-Filed Claims or to any other proofs of claim that may be asserted against the Debtor’s estate. Should one or more of the grounds of objection stated herein be overruled, the Reorganized Debtor reserves the right to object to the Late-Filed Claims on any other ground that bankruptcy or non-bankruptcy law permits. 16. Notwithstanding anything contained herein or the attached exhibits, nothing herein shall be construed as a waiver of any rights, including, but not limited, the exercise the estate’s rights of setoff against the holders of such claims. Compliance with Local Rule 3007-1 17. The Reorganized Debtor, by and through its counsel, state that, to the best of its knowledge, information and belief, this First Omnibus Objection and related exhibits comply with the requirements of Local Rule 3007-1. To the extent this First Omnibus Objection does not comply in all respects with the requirements of Local Rule 3007-1, the undersigned believes such deviations are not material and respectfully requests that such requirements be waived. Notice 18. Notice of this First Omnibus Objection has been given to the following parties or, in lieu thereof, to their counsel, if known: (a) the Office of the United States Trustee for the District of Delaware; (b) those parties whose claims are listed in Exhibit A to the proposed attached hereto; and (c) those parties requesting notice pursuant to Bankruptcy Rule 2002. The

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Reorganized Debtor submits that, in light of the nature of the relief requested, no other or further notice need be given. Conclusion WHEREFORE, for the reasons set forth herein, the Reorganized Debtor respectfully requests that this Court approve the relief requested in this First Omnibus Objection and grant such other and further relief as is just and proper. Dated: May 28, 2021 Respectfully submitted, Wilmington, Delaware GREENBERG TRAURIG, LLP By: /s/ Dennis A. Meloro Dennis A. Meloro (DE Bar No. 4435) The Nemours Building 1007 North Orange Street, Suite 1200 Wilmington, Delaware 19801 Telephone: (302) 661-7000 Email: melorod@gtlaw.com Counsel for the Reorganized Debtor

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