Full title: Withdrawal (re:34 Objection, 36 Objection, 38 Objection) filed by STIHL Incorporated. Proof of service. (Lahn, Connie) (Entered: 01/14/2021)
Document posted on Jan 13, 2021 in the bankruptcy, 3 pages and 0 tables.
UNITED STATES BANKRUPTCY COURT
DISTRICT OF MINNESOTA
Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037
Debtor. Chapter 11
WITHDRAWAL OF STIHL INCORPORATED’S: (1) OBJECTION AND
RESERVATION OF RIGHTS TO DEBTOR’S MOTION FOR AN INTERIM AND FINAL ORDER (I) GRANTING EXPEDITED RELIEF, (II) AUTHORIZING THE DEBTOR TO ASSUME THE CONSULTING AGREEMENT WITH LIQUIDATION
CONSULTANT, (III) AUTHORIZING AND APPROVING THE CONDUCT OF STORE CLOSING SALES, WITH SUCH SALES TO BE FREE AND CLEAR OF ALL LIENS, CLAIMS, AND ENCUMBRANCES, (IV) PERMITTING THE DEBTOR TO ABANDON ANY PROPERTY THAT IS BURDENSOME OR OF INCONSEQUENTIAL VALUE, AND (V) GRANTING RELATED RELIEF; (2) LIMITED OBJECTION TO DEBTOR’S MOTION FOR ORDER (I) GRANTING EXPEDITED RELIEF AND (II)
AUTHORIZING THE USE OF CASH COLLATERAL ON AN INTERIM AND FINAL BASIS; AND (3) OBJECTION TO DEBTOR’S MOTION FOR ORDER (I) GRANTING EXPEDITED RELIEF AND (II) ESTABLISHING PROCEDURES FOR THE RESOLUTION OF RECLAMATION CLAIMS AND ADMINISTRATIVE CLAIMS PURSUANT TO SECTION 506(B)(9) OF THE BANKRUPTCY CODE
STIHL Incorporated (“STIHL”), by and through its undersigned counsel, withdraws its following objections to motions filed by Tea Olive I, LLC d/b/a Stock+Field (“Debtor”):
Objection and Reservation of Rights to Debtor’s Motion for an Interim and Final Order (I) Granting Expedited Relief, (II) Authorizing the Debtor to Assume the Consulting Agreement with Liquidation Consultant, (III) Authorizing and Approving the Conduct of Store Closing Sales, with Such Sales to be Free and Clear of All Liens, Claims, and Encumbrances, (IV) Permitting the Debtor to Abandon Any Property That is Burdensome or of Inconsequential Value, and (V) Granting Related Relief [ECF No. 36]; Limited Objection to Debtor’s Motion for Order (I) Granting Expedited Relief and (II) Authorizing the Use of Cash Collateral on an Interim and Final Basis [ECF No. 34]; and Objection to Debtor’s Motion For Order (I) Granting Expedited Relief And (Ii) Establishing Procedures For The Resolution Of Reclamation Claims And Administrative Claims Pursuant To Section 506(B)(9) Of The Bankruptcy Code [ECF No. 38].
STIHL reserves the right to raise any objections at the final hearing.
Dated: January 14, 2021. Respectfully Submitted,
BARNES & THORNBURG LLP
/e/ Connie A. Lahn
Connie A. Lahn (#0269219)
Molly N. Sigler (#0399122)
Barnes & Thornburg LLP
2800 Capella Tower
225 South Sixth Street
Minneapolis, MN 55402-4662
Telephone: (612) 333-2111
Facsimile: (612) 333-6798