HTML Document View

Full title: Stipulation, Regarding Extension of Time to Object to Proof of Claim No. 55 of Gregory Corona Filed by Interested Party Wave Computing Liquidating Trust. (Wynne, Richard) (Entered: 08/23/2021)

Document posted on Aug 22, 2021 in the bankruptcy, 7 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

The Reorganized Debtors in these chapter 11 cases are: Wave Computing, Inc., MIPS Tech, Inc., Hellosoft, Inc.,WHEREAS, Mr. Corona filed Proof of Claim No. 912The deadline to object to the Corona Claim shall be extended from August 25, 20225 26 2 The Proof of Claim is referred to in the register maintained by Donlin Recano & Company as Claim No. 91, but is 27 referred to in the register maintained by the Court as Claim No. 55 in In re Wave Computing, Inc., Case No. 20-50692.17 18 [No Hearing Requested] 19 20 Upon the stipulation (the “Stipulation”)2, dated August 23, 2021, between Wave Computin21 Liquidating Trust (the “Liquidating Trust”) and Gregory Corona (“Mr. Corona,” together with th22 Liquidating Trust, the “Parties” and each, individually, a “Party”), by and through their respectiv23 undersigned counsel; and the relief requested in the Stipulation being in the best interests of th24 25 26 1 The Reorganized Debtors in these chapter 11 cases are: Wave Computing, Inc., MIPS Tech, Inc., Hellosoft, Inc., Wave Computing (UK) Limited, Imagination Technologies, Inc., Caustic Graphics, Inc., and MIPS Tech, LLC.

List of Tables

Document Contents

1 Richard L. Wynne (Bar No. 120349) richard.wynne@hoganlovells.com 2 Bennett L. Spiegel (Bar No. 129558) bennett.spiegel@hoganlovells.com 3 Edward J. McNeilly (Bar No. 314588) edward.mcneilly@hoganlovells.com 4 HOGAN LOVELLS US LLP 1999 Avenue of the Stars, Suite 1400 5 Los Angeles, California 90067 Telephone: (310) 785-4600 6 Facsimile: (310) 785-4601 7 Attorneys for Wave Computing Liquidating Trust 8 9 UNITED STATES BANKRUPTCY COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN JOSE DIVISION 12 In re Case No. 20-50682 (MEH) 13 Chapter Number 11 (Jointly Administered) 14 WAVE COMPUTING, INC., et al., STIPULATION REGARDING EXTENSION OF15 TIME TO OBJECT TO PROOF OF CLAIM NO Reorganized Debtors1. 55 OF GREGORY CORONA 16 17 [No Hearing Requested] 18 19 20 21 This stipulation (the “Stipulation”) is made and entered into by and between Wav22 Computing Liquidating Trust (the “Liquidating Trust”) and Gregory Corona (“Mr. Corona,23 together with the Liquidating Trust, the “Parties” and each, individually, a “Party”), by and throug24 their respective undersigned counsel. 25 26 1 The Reorganized Debtors in these chapter 11 cases are: Wave Computing, Inc., MIPS Tech, Inc., Hellosoft, Inc., 27 Wave Computing (UK) Limited, Imagination Technologies, Inc., Caustic Graphics, Inc., and MIPS Tech, LLC. TheReorganized Debtors’ mailing address is 3201 Scott Blvd, Santa Clara, CA 95054. 28

1

1 RECITALS 2 WHEREAS, the Effective Date of The Sixth Amended Joint Chapter 11 Plan 3 Reorganization Of Wave Computing, Inc. And Its Debtor Affiliates [Docket No. 1129] (the “Plan4 occurred on February 26, 2021 [Dkt. No. 1227]; 5 WHEREAS, the Plan provides that the Claim Objection Deadline is 180 days after th6 7 Effective Date, subject to any extensions approved by an order of the Bankruptcy Court, whic8 makes August 25, 2021 the Claim Objection Deadline; 9 WHEREAS, Mr. Corona filed Proof of Claim No. 912 (the “Corona Claim”) in the chapte10 11 case of Wave in an unliquidated amount; 11 WHEREAS, the Liquidating Trust disputes the Corona Claim; 12 WHEREAS, the Parties, through their respective counsel, are engaged in good fait13 discussions with respect to a potential resolution of such dispute; 14 15 WHEREAS, the Parties wish to continue such good faith discussions and to avoid the tim16 and expense that would be incurred if a claim objection were required to be filed to comply wit17 the August 25, 2021 Claim Objection Deadline; 18 WHEREAS, the Reorganized Debtors, through counsel, have indicated that they do n19 object to this Stipulation; 20 NOW, THEREFORE, the Parties hereby stipulate as follows: 21 1. Capitalized terms used, but not defined, in this Stipulation (including the Recital22 23 shall have the meanings ascribed to such terms in the Plan. 24 2. The deadline to object to the Corona Claim shall be extended from August 25, 20225 26 2 The Proof of Claim is referred to in the register maintained by Donlin Recano & Company as Claim No. 91, but is 27 referred to in the register maintained by the Court as Claim No. 55 in In re Wave Computing, Inc., Case No. 20-50692. 28

2

1 to February 25, 2022. The Liquidating Trust may seek further extensions of the deadline to obje2 to the Corona Claim. Nothing in this Stipulation shall extend the Claim Objection Deadline for an3 Claim other than the Corona Claim. 4 3. This Stipulation is without prejudice to the rights of the Reorganized Debtors t5 pursue their own objection to the Corona Claim. 6 7 4. The Bankruptcy Court shall retain jurisdiction with respect to all matters arising 8 from or related to the implementation, interpretation, or enforcement of this Stipulation. 9 SO STIPULATED: 10 11 Dated: August 23, 2021 HOGAN LOVELLS US LLP 12 By: /s/ Richard L. Wynne____ 13 Richard L. Wynne Attorneys for Wave Computing Liquidating 14 Trust 15 Dated: August 23, 2021 PERKINS COIE LLP 16 17 By: /s/ Sara L. Chenetz_____ Sara L. Chenetz 18 Attorneys for Gregory Corona 19 20 21 22 23 24 25 26 27 28

3

1 EXHIBIT A Proposed Order 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

4

1 Richard L. Wynne (Bar No. 120349) richard.wynne@hoganlovells.com 2 Bennett L. Spiegel (Bar No. 129558) bennett.spiegel@hoganlovells.com 3 Edward J. McNeilly (Bar No. 314588) edward.mcneilly@hoganlovells.com 4 HOGAN LOVELLS US LLP 1999 Avenue of the Stars, Suite 1400 5 Los Angeles, California 90067 Telephone: (310) 785-4600 6 Facsimile: (310) 785-4601 7 Attorneys for Wave Computing Liquidating Trust 8 9 UNITED STATES BANKRUPTCY COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN JOSE DIVISION 12 In re Case No. 20-50682 (MEH) 13 WAVE COMPUTING, INC., et al., Chapter Number 11 (Jointly Administered) 14 Reorganized Debtors1. ORDER GRANTING STIPULATION 15 REGARDING EXTENSION OF TIME TO OBJECT TO PROOF OF CLAIM NO. 55 OF 16 GREGORY CORONA 17 18 [No Hearing Requested] 19 20 Upon the stipulation (the “Stipulation”)2, dated August 23, 2021, between Wave Computin21 Liquidating Trust (the “Liquidating Trust”) and Gregory Corona (“Mr. Corona,” together with th22 Liquidating Trust, the “Parties” and each, individually, a “Party”), by and through their respectiv23 undersigned counsel; and the relief requested in the Stipulation being in the best interests of th24 25 26 1 The Reorganized Debtors in these chapter 11 cases are: Wave Computing, Inc., MIPS Tech, Inc., Hellosoft, Inc., Wave Computing (UK) Limited, Imagination Technologies, Inc., Caustic Graphics, Inc., and MIPS Tech, LLC. The27 Reorganized Debtors’ mailing address is 3201 Scott Blvd, Santa Clara, CA 95054. 2 Capitalized terms used but not defined herein shall have the meanings ascribed to such terms in the Stipulation. 28

5

1 Reorganized Debtors’ estates, their creditors and other parties in interest; and the relief requeste2 in the Stipulation being in the best interests of the beneficiaries of the Liquidating Trust; and aft3 due deliberation and sufficient cause appearing therefor, 4 IT IS HEREBY ORDERED THAT: 5 1. The Stipulation is approved. 6 7 2. The deadline to object to the Corona Claim shall be extended from August 25, 2028 to February 25, 2022. The Liquidating Trust may seek further extensions of the deadline to obje9 to the Corona Claim. Nothing in this Order shall extend the Claim Objection Deadline for an10 Claim other than the Corona Claim. 11 3. This Stipulation is without prejudice to the rights of the Reorganized Debtors t12 pursue their own objection to the Corona Claim. 13 4. The Bankruptcy Court shall retain jurisdiction to hear and determine all matter14 15 arising from or related to the implementation, interpretation, or enforcement of the Stipulation 16 this Order. 17 ***END OF ORDER*** 18 19 20 21 22 23 24 25 26 27 28

6

CERTIFICATE OF SERVICE I hereby certify that on August 23, 2021, a true and correct copy of the foregoing document was filed and served via the Court’s electronic case filing and noticing system to all parties registered to receive electronic notices in this matter and via U.S. Mail to the following party: Sara L. Chenetz Perkins Coie LLP 1888 Century Park East, Suite 1700 Los Angeles, CA 90067-1721 /s/ Richard L. Wynne Richard L. Wynne

7