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Full title: Emergency Motion filed by Debtor TPS Oldco, LLC to Extend Time to Respond [Re: 500 Objection to Claim] with certificate of service. (Ricotta, Paul) (Entered: 05/28/2021)

Document posted on May 27, 2021 in the bankruptcy, 4 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

TPS Oldco, LLC (f/k/a The Paper Store, LLC) and its debtor affiliate, TPS Holdings, LLC, as debtors and debtors-in-possession in the above-captioned chapter 11 cases (collectively, the “Debtors”), hereby request the entry of an order extending the deadline by which Alex and Ani (“A&A”) may respond to the Debtors’ First Omnibus Objection to Certain (I) Duplicative Claims, (II) Assigned Claims, (III)No Liability Claims, (IV) Satisfied Claims, (V) Reclassified and/or Modified Claims, (VI) Late Claims, (VII) Amended and Superseded Claims, and (VIII) Wrong Debtor ClaimsThe Debtors’ corporate headquarters and service address is c/o G2 Capital Advisors LLC | 420 Boylston Street, Suite 302 | Boston MA 02116 | Attention: Don Van der Wiel, Managing Director.On April 26, 2021, the Debtors filed the Omnibus Objection seeking, among other things, to disallow and expunge a claim filed by A&A against debtor TPS Holdings, LLC [Claim No. 230] on the basis that such debtor entity does not have any liability with respect to A&A’s asserted claim.No Liability Claims, (IV) Satisfied Claims, (V) Reclassified and/or Modified Claims, (VI) Late Claims, (VII) Amended and Superseded Claims, and (VIII) Wrong Debtor Claims (the “Motion”) was filed via the Court’s CM/ECF electronic filing system (“CM/ECF”), which sent notice of the Motion to all parties receiving notification through CM/ECF.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MASSACHUSETTS (CENTRAL DIVISION) ------------------------------------------------------------x : In re : Chapter 11 : TPS Oldco, LLC, et al., : Case No. 20-40743 (CJP) : Debtors.1 : (Jointly Administered) : ------------------------------------------------------------x ASSENTED TO MOTION TO EXTEND THE DEADLINE FOR ALEX AND ANI TO RESPOND TO THE DEBTORS’ FIRST OMNIBUS OBJECTION TO CERTAIN (I) DUPLICATIVE CLAIMS, (II) ASSIGNED CLAIMS, (III) NO LIABILITY CLAIMS, (IV) SATISFIED CLAIMS, (V) RECLASSIFIED AND/OR MODIFIED CLAIMS, (VI) LATE CLAIMS, (VII) AMENDED AND SUPERSEDED CLAIMS, AND (VIII) WRONG DEBTOR CLAIMS (Emergency Determination Requested) TPS Oldco, LLC (f/k/a The Paper Store, LLC) and its debtor affiliate, TPS Holdings, LLC, as debtors and debtors-in-possession in the above-captioned chapter 11 cases (collectively, the “Debtors”), hereby request the entry of an order extending the deadline by which Alex and Ani (“A&A”) may respond to the Debtors’ First Omnibus Objection to Certain (I) Duplicative Claims, (II) Assigned Claims, (III) No Liability Claims, (IV) Satisfied Claims, (V) Reclassified and/or Modified Claims, (VI) Late Claims, (VII) Amended and Superseded Claims, and (VIII) Wrong Debtor Claims [Docket No. 500] (the “Omnibus Objection”). In support of this motion, the Debtors respectfully represent as follows: 1. On July 14, 2020, the Debtors each commenced with this Court a voluntary case under chapter 11 of the Bankruptcy Code. The Debtors are authorized to continue operating their 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are TPS Oldco, LLC (2442) and TPS Holdings, LLC (9193). The Debtors’ corporate headquarters and service address is c/o G2 Capital Advisors LLC | 420 Boylston Street, Suite 302 | Boston MA 02116 | Attention: Don Van der Wiel, Managing Director.

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businesses and managing their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. The Debtors’ chapter 11 cases have been jointly administered for procedural purposes only pursuant to Rule 1015(b) of the Bankruptcy Rules and MLBR 1015-1. On July 27, 2020, the United States Trustee appointed an Official Committee of Unsecured Creditors. See Docket No. 134. 2. On April 26, 2021, the Debtors filed the Omnibus Objection seeking, among other things, to disallow and expunge a claim filed by A&A against debtor TPS Holdings, LLC [Claim No. 230] on the basis that such debtor entity does not have any liability with respect to A&A’s asserted claim. See Omnibus Objection, ¶ 17. A hearing on the Omnibus Objection is scheduled for June 9, 2021 and the deadline for parties to respond to the Omnibus Objection is May 28, 2021 at 4:30 p.m. (ET) (the “Objection Deadline”). See Notice of Telephonic Nonevidentiary Hearing[Docket No. 501]. 3. Counsel for the Debtors and A&A have been engaged in active discussions regarding, inter alia, a resolution of the relief requested in the Omnibus Objection. In light of such ongoing negotiations, counsel for A&A has requested that the Objection Deadline for A&A be extended to June 4, 2021 at 4:30 p.m. (ET). Given that such negotiations, if successful, would resolve the parties’ dispute with respect to the Omnibus Objection, the Debtors believe that an extension of the Objection Deadline for A&A is in the best interests of the Debtors and their creditors, will further the interests of judicial economy, and, therefore, consent to the request. 4. The Debtors require this relief on an emergency basis because the Objection Deadline is May 28, 2021 at 4:30 p.m. (ET).

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WHEREFORE, the Debtors respectfully request that the Court enter an order extending the Objection Deadline for A&A from May 28, 2021 at 4:30 p.m. (ET) to June 4, 2021 at 4:30 p.m. (ET), and granting such other and further relief as the Court may deem just and appropriate. Dated: May 28, 2021 Boston, Massachusetts /S/PAUL J.RICOTTA Paul J. Ricotta, Esq. (BBO# 552028) Timothy J. McKeon, Esq. (BBO# 569395) MINTZ LEVIN COHN FERRIS GLOVSKY AND POPEO, P.C. One Financial Center Boston, MA 02111 Tel: 617-542-6000 pjricotta@mintz.com tjmckeon@mintz.com -and- Kaitlin R. Walsh, Esq. (admitted pro hac vice) Chrysler Center 666 Third Avenue New York, NY 10017 Tel: 212-935-3000 krwalsh@mintz.com Attorneys for Debtors and Debtors-in-Possession

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MASSACHUSETTS (CENTRAL DIVISION) ------------------------------------------------------------x : In re : Chapter 11 : TPS Oldco, LLC, et al., : Case No. 20-40743 (CJP) : Debtors.1 : (Jointly Administered) : ------------------------------------------------------------x CERTIFICATE OF SERVICE I, Paul J. Ricotta, hereby certify that the foregoing Joint Motion to Extend the Deadline for Alex and Ani to Respond to the Debtors’ First Omnibus Objection to Certain (I) Duplicative Claims, (II) Assigned Claims, (III) No Liability Claims, (IV) Satisfied Claims, (V) Reclassified and/or Modified Claims, (VI) Late Claims, (VII) Amended and Superseded Claims, and (VIII) Wrong Debtor Claims (the “Motion”) was filed via the Court’s CM/ECF electronic filing system (“CM/ECF”), which sent notice of the Motion to all parties receiving notification through CM/ECF. Dated: May 28, 2021 Boston, Massachusetts /S/PAUL J.RICOTTA Paul J. Ricotta, Esq. (BBO# 552028) MINTZ LEVIN COHN FERRIS GLOVSKY AND POPEO, P.C. One Financial Center Boston, MA 02111 Tel: 617-542-6000 Email: pjricotta@mintz.com 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are TPS Oldco, LLC (2442) and TPS Holdings, LLC (9193). The Debtors’ corporate headquarters and service address is c/o G2 Capital Advisors LLC | 420 Boylston Street, Suite 302 | Boston MA 02116 | Attention: Don Van der Wiel, Managing Director.

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