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Full title: Exhibit(s) Stipulation Fixing and Allowing IGS Realty Co.'s Claim Filed by MUJI U.S.A. Limited. (Meloro, Dennis) (Entered: 05/28/2021)

Document posted on May 27, 2021 in the bankruptcy, 5 pages and 0 tables.

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WHEREAS, on July 10, 2020, the Debtor filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code in the United States Bankruptcy Court for the District of Delaware (the “Court”); WHEREAS, prior to the Petition Date, Debtor and IGS were parties to a lease agreement (the “Lease”) for the lease of storage space at 336 West 37th Street, Basement 10, New York, NY; WHEREAS, as of the date of this Stipulation, IGS timely filed: (i) one (1) proof of claim against the Debtor’s estate in the amount of $7,945.40 for prepetition arrears and charges on the Lease, which claim is reflected on the claims register (the “Claims Register”) maintained by the Court-appointed Claims and Noticing Agent, Donlin, Recano & Company, Inc. in the amount of $69,987.91 on account of the Debtor’s rejection of the Lease, which claim is reflected on the Claim Register as claim number 24 (“Claim 24”); WHEREAS, on December 21, 2020, the Court entered an order [Docket No. 277] confirming the Amended Chapter 11 Plan of Reorganization of MUJI U.S.A. Limited Pursuant to Chapter 11 of the Bankruptcy Code (as Modified) (“Plan”)[Docket No. 286]; WHEREAS, pursuant to Section VII(B) of the Plan, the Reorganized Debtor has the sole authority to, among other things, settle or compromise any disputed claim and administer and adjust the Claim Register without any further notice to or action, order, or approval by the Court; WHEREAS, pursuant to the Plan, General Unsecured Claims (as defined in the Plan) against the Debtor’s estate are classified as “Class 3 Claims”; WHEREAS, the Reorganized Debtor has informed IGS that it objects to the total amount asserted in Claims 23 and 24, and also objects to the administrative expense priority IGS seeks for Claim 24; WHEREAS, through their counsel, the Parties have conferred and engaged in negotiations with respect to the allowance of Claims 23 and 24, and wish to enter into the Stipulation fixing and allowing Claims 23 and 24 on the term set forth herein. Claim 24 shall be deemed fixed and Allowed (as defined in the Plan) as a General Unsecured Claim in the reduced amount of $20,619.95 (“Allowed Claim 24” and together with Allowed Claim 23, the “Allowed Claims”).

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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. STIPULATION FIXING AND ALLOWING IGS REALTY CO.’S CLAIM 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”) and IGS Realty Co. (“IGS” and together with the Reorganized Debtor, the “Parties”) hereby stipulate and agree to the following (the “Stipulation”): Recitals WHEREAS, on July 10, 2020, the Debtor filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code in the United States Bankruptcy Court for the District of Delaware (the “Court”); WHEREAS, prior to the Petition Date, Debtor and IGS were parties to a lease agreement (the “Lease”) for the lease of storage space at 336 West 37th Street, Basement 10, New York, NY; WHEREAS, as of the date of this Stipulation, IGS timely filed: (i) one (1) proof of claim against the Debtor’s estate in the amount of $7,945.40 for prepetition arrears and charges on the Lease, which claim is reflected on the claims register (the “Claims Register”) maintained by the Court-appointed Claims and Noticing Agent, Donlin, Recano & Company, Inc. (“DRC”) as claim number 23 (“Claim 23”), and (ii) one (1) proof of administrative claim against the Debtor’s estate 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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in the amount of $69,987.91 on account of the Debtor’s rejection of the Lease, which claim is reflected on the Claim Register as claim number 24 (“Claim 24”); WHEREAS, on December 21, 2020, the Court entered an order [Docket No. 277] confirming the Amended Chapter 11 Plan of Reorganization of MUJI U.S.A. Limited Pursuant to Chapter 11 of the Bankruptcy Code (as Modified) (“Plan”) [Docket No. 277-1]; WHEREAS, the Effective Date (as defined in the Plan) occurred on December 31, 2020 [Docket No. 286]; WHEREAS, pursuant to Section VII(B) of the Plan, the Reorganized Debtor has the sole authority to, among other things, settle or compromise any disputed claim and administer and adjust the Claim Register without any further notice to or action, order, or approval by the Court; WHEREAS, pursuant to the Plan, General Unsecured Claims (as defined in the Plan) against the Debtor’s estate are classified as “Class 3 Claims”; WHEREAS, the Reorganized Debtor has informed IGS that it objects to the total amount asserted in Claims 23 and 24, and also objects to the administrative expense priority IGS seeks for Claim 24; WHEREAS, through their counsel, the Parties have conferred and engaged in negotiations with respect to the allowance of Claims 23 and 24, and wish to enter into the Stipulation fixing and allowing Claims 23 and 24 on the term set forth herein. NOW THEREFORE, IN CONSIDERATION OF THE FOREGOING, THE MUTUAL COVENANTS HEREIN CONTAINED, AND FOR GOOD AND VALUABLE CONSIDERATION, THE RECEIPT AND SUFFICIENCY OF WHICH IS ACKNOWLEDGED BY ALL PARTIES, THE PARTIES HERETO AGREE TO THE FOLLOWING TERMS: 1. This Stipulation, and the obligations of the Parties hereunder, shall be in full force and effect upon execution hereof by all Parties. Each of the undersigned warrants and represents

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that it has full and requisite authority to enter into this Stipulation and bind its respective client to the terms hereof. 2. The foregoing recitals are hereby fully incorporated into and made an express part of this Stipulation. 3. IGS represents and warrants that it (i) is the sole owner and holder of Claims 23 and 24, and (ii) has not sold, assigned or otherwise transferred any portion of either Claim 23 or Claim 24 to any third party. 4. Upon the execution of this Stipulation by the Parties: a. Claim 23 shall be deemed fixed and Allowed (as defined in the Plan) as a General Unsecured Claim in the amount of $7,954.40 (“Allowed Claim 23”); and b. Claim 24 shall be deemed fixed and Allowed (as defined in the Plan) as a General Unsecured Claim in the reduced amount of $20,619.95 (“Allowed Claim 24” and together with Allowed Claim 23, the “Allowed Claims”). 5. The Allowed Claims shall be classified as Class 3 Claims, and IGS shall receive on account of the Allowed Claims its pro rata distribution from the GUC Cash Distribution Pool (as such term is defined in the Plan), in accordance with the terms of the Plan. 6. Other than the Allowed Claims, IGS has and shall have no other claim in the above-captioned chapter 11 case, including any administrative expense claim. IGS further agrees it shall not file any further proof of claim. 7. The Reorganized Debtor shall provide a copy of the Stipulation to DRC to update the Claims Register. 8. This Stipulation may not be modified other than by a signed writing executed by each of the Parties hereto or by an order of the Court. 9. This Stipulation is the result of a compromise between the Parties and neither the facts nor the terms of this Stipulation shall be offered or received in evidence in any action or

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proceeding for any purpose, except in an action or proceeding arising out of or in connection with this Stipulation. 10. In the event of any ambiguity in this Stipulation, no inferences shall be drawn against any Party on the basis of authorship of this Stipulation. 11. This Stipulation shall remain binding on the Parties and all of their successors and assigns. 12. This Stipulation may be executed in one or more counterparts, each of which shall constitute an original, but all of which, when taken together, shall constitute one and the same instrument. 13. This Stipulation may be executed and delivered by electronic signature. 14. The Court shall retain jurisdiction to hear and determine any matter arising from this Stipulation. [Signature Page Follows]

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Dated: May 27, 2021 GREENBERG TRAURIG, LLP By: /s/ __ Dennis A. Meloro____________ Dennis A. Meloro (DE Bar No. 4435) 1007 North Orange Street, Suite 1200 Wilmington, Delaware 19801 Tel. (302) 661-7000 Email: melorod@gtlaw.com Counsel for the Reorganized Debtor Dated: May 25, 2021 GARY J. WACHTEL, ESQ. By: /s/ _Gary J. Wachtel_______________ Gary J. Wachtel 450 7th Avenue, Suite 1905 New York, New York 10123 Tel. (212) 371-6500 Email: info@garywachtel.com Counsel for IGS Realty Co.

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