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Full title: Certification of Counsel Regarding Order Approving Stipulation Between the BL Restaurants GUC Trust and American Express Travel Related Services (related document(s)[942], [943]) Filed by BL Restaurants GUC Trust. (Attachments: # (1) Exhibit A - Proposed Order # (2) Exhibit 1 to Proposed Order (Stipulation)) (Patterson, Morgan)

Document posted on Jan 11, 2022 in the bankruptcy, 2 pages and 0 tables.

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the “Stipulation”)2 attached as Exhibit 1 to the proposed order (the “Proposed Order”) attached hereto as Exhibit A: 1. Specifically, the Stipulation reinstates the claims filed by the Claimant in certain agreed amounts which were disallowed and/or modified pursuant to the (i) Order Sustaining First OmnibusInsufficient 1 The Debtors in these cases are as follows: BL Restaurants Holding, LLC; BL Restaurant Operations, LLC; BL Restaurant Franchises, LLC; and BL Hunt Valley, LLC.Documentation Claims [Docket No. 942] (the “First Omnibus Order”) and (ii) Order Sustaining Second Omnibus (Substantive)Objection of the BL Restaurants GUC Trust to Certain (A) No Liability Claims; (B) Overstated Claims; (C) Misclassified Claims; and (D) Unliquidated Claims

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 BL RESTAURANTS HOLDING, LLC, et al.,1 Case No. 20-10156 (CTG) Debtors. (Jointly Administered) Related Docket Nos. 942 & 943 CERTIFICATION OF COUNSEL REGARDING ORDER APPROVING STIPULATION BETWEEN THE BL RESTAURANTS GUC TRUST AND AMERICAN EXPRESS TRAVEL RELATED SERVICES The undersigned counsel to the BL Restaurants GUC Trust (the “Trust”) hereby certifies as follows regarding the Stipulation Between the BL Restaurants GUC Trust and American Express Travel Related Services (the “Stipulation”)2 attached as Exhibit 1 to the proposed order (the “Proposed Order”) attached hereto as Exhibit A: 1. The Trust and American Express Travel Related Services (“Claimant”) entered into the Stipulation on January 12, 2022. Pursuant to and as more fully set forth in the Stipulation, the Trust and the Claimant have fully resolved the claims filed by the Claimant in the above-captioned bankruptcy cases (the “Cases”). 2. Specifically, the Stipulation reinstates the claims filed by the Claimant in certain agreed amounts which were disallowed and/or modified pursuant to the (i) Order Sustaining First Omnibus (Non-Substantive) Objection of the BL Restaurants GUC Trust to Certain (A) Duplicative Claims; (B) Late Filed Claims; (C) Amended and Superseded Claims; and (D) Insufficient 1 The Debtors in these cases are as follows: BL Restaurants Holding, LLC; BL Restaurant Operations, LLC; BL Restaurant Franchises, LLC; and BL Hunt Valley, LLC. 2 Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Stipulation.

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Documentation Claims [Docket No. 942] (the “First Omnibus Order”) and (ii) Order Sustaining Second Omnibus (Substantive) Objection of the BL Restaurants GUC Trust to Certain (A) No Liability Claims; (B) Overstated Claims; (C) Misclassified Claims; and (D) Unliquidated Claims [Docket No. 943] (the “Second Omnibus Order”). WHEREFORE, for the reasons herein and the Stipulation, the Trust respectfully requests that the Court enter the Proposed Order approving the Stipulation at the convenience of the Court. Dated: Wilmington, Delaware WOMBLE BOND DICKINSON (US) LLP January 12, 2022 /s/ Morgan L. Patterson Matthew P. Ward (DE No. 4471) Morgan L. Patterson (DE No. 5388) 1313 North Market Street, Suite 1200 Wilmington, Delaware 19801 Tel: (302) 252-4320 Fax: (302) 252-4330 - and - KELLEY DRYE & WARREN LLP Eric R. Wilson (admitted pro hac vice) Jason R. Adams (admitted pro hac vice) Lauren S. Schlussel (admitted pro hac vice) 3 World Trade Center 175 Greenwich Street New York, New York 10007 Tel: (212) 808-7800 Fax: (212) 808-7897 Counsel to the BL Restaurants GUC Trust 2

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