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Full title: Certificate of No Objection for Plaintiffs Motion for Orders Establishing Streamlined Procedures Governing Adversary Proceedings Brought by Plaintiff Pursuant to Sections 502, 547, 548, 549 and 550 of the Bankruptcy Code (related document(s)[1569]) Filed by FI Liquidating Trust. (Attachments: # (1) Exhibit A # (2) Exhibit B # (3) Exhibit C) (Johnson, Ericka)

Document posted on Oct 17, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

I, Ericka F. Johnson of Womble Bond Dickinson (US) LLP and N. Christopher Griffiths of Connolly Gallagher LLP, counsel to the FI Liquidation Trust of the above-captioned debtors (the “Trustee” or “Plaintiff”), hereby certify that as of the date hereof, I have received no answer, objection or other responsive pleading to Plaintiff’s Motion For Orders Establishing Streamlined Procedures Governing Adversary Proceedings Brought by Plaintiff Pursuant To Sections 502, 547, 548, 549 And 550 Of The Bankruptcy Code (filed on September 28, 2021, at Docket No. 1569) (the “Motion”).Fred’s Stores of Tennessee, Inc. (9888); National Equipment Management and Leasing, Inc. (4296); National Pharmaceutical Network, Inc. (9687); Reeves-Sain Drug Store, Inc. (4510); Summit Properties-Jacksboro, LLC (9161); Summit Properties-Bridgeport, LLC (2200); and 505 N. Main Opp, LLC (5850).The undersigned further certifies that I have caused the Court’s docket in these cases to be reviewed and no answer, objection or other responsive pleading to the Motion appears thereon.Telephone: (302) 252-4320 Facsimile: (302) 252-4330 E-mail: matthew.ward@wbd-us.com ericka.johnson@wbd-us.com -and- CONNOLLY GALLAGHER LLP ** /s/ lhatfield@connollygallagher.com -and- ASK LLP Joseph L. Steinfeld, Jr., Esq., MN SBN 0266292 Kara E. Casteel, Esq.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 Fred’s, Inc., et al.,1 Case No. 19-11984 (CTG) Debtors. (Jointly Administered) FI Liquidating Trust, Plaintiff, vs. Adv. No. See Exhibit “A” Defendants Listed on Exhibit “A”, Defendant. CERTIFICATE OF NO OBJECTION FOR PLAINTIFF’S MOTION FOR ORDERS ESTABLISHING STREAMLINED PROCEDURES GOVERNING ADVERSARY PROCEEDINGS BROUGHT BY PLAINTIFF PURSUANT TO SECTIONS 502, 547, 548, 549 AND 550 OF THE BANKRUPTCY CODE I, Ericka F. Johnson of Womble Bond Dickinson (US) LLP and N. Christopher Griffiths of Connolly Gallagher LLP, counsel to the FI Liquidation Trust of the above-captioned debtors (the “Trustee” or “Plaintiff”), hereby certify that as of the date hereof, I have received no answer, objection or other responsive pleading to Plaintiff’s Motion For Orders Establishing Streamlined Procedures Governing Adversary Proceedings Brought by Plaintiff Pursuant To Sections 502, 547, 548, 549 And 550 Of The Bankruptcy Code (filed on September 28, 2021, at Docket No. 1569) (the “Motion”). 1 The Debtors in these Chapter 11 Cases, along with the last four digits of each Debtor’s federal tax identification number, are: Fred’s, Inc. (4010); Fred’s Stores of Tennessee, Inc. (9888); National Equipment Management and Leasing, Inc. (4296); National Pharmaceutical Network, Inc. (9687); Reeves-Sain Drug Store, Inc. (4510); Summit Properties-Jacksboro, LLC (9161); Summit Properties-Bridgeport, LLC (2200); and 505 N. Main Opp, LLC (5850). The Debtors’ current mailing address is c/o FI Liquidating Trust, 27 Crimson King Drive, Bear, DE 19701.

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The undersigned further certifies that I have caused the Court’s docket in these cases to be reviewed and no answer, objection or other responsive pleading to the Motion appears thereon. Pursuant to the Notice of Motion, objections to the Motion were to be filed and served no later than October 12, 2021, at 4:00 p.m. (EDT). It is hereby respectfully requested that the proposed Order as originally filed with the Motion be entered at its earliest convenience of the Court. Dated: October 18, 2021 WOMBLE BOND DICKINSON (US) LLP /s/ Ericka F. Johnson____ _____ Matthew P. Ward, Esq. (No. 4471) Ericka F. Johnson, Esq. (No. 5024) 1313 North Market Street, Suite 1200 Wilmington, Delaware 19801 Telephone: (302) 252-4320 Facsimile: (302) 252-4330 E-mail: matthew.ward@wbd-us.com ericka.johnson@wbd-us.com -and- CONNOLLY GALLAGHER LLP ** /s/ N. Christopher Griffiths N. Christopher Griffiths (#5180) Lisa Hatfield (#4967) 1201 North Market Street, 20th Floor Wilmington, Delaware 19801 Telephone: (302) 888-6313 Email: cgriffiths@connollygallagher.com lhatfield@connollygallagher.com -and-

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ASK LLP Joseph L. Steinfeld, Jr., Esq., MN SBN 0266292 Kara E. Casteel, Esq. MN SBN 0389115 2600 Eagan Woods Drive, Suite 400 St. Paul, MN 55121 Telephone: (651) 289-3846 Fax: (651) 406-9676 Email: kcasteel@askllp.com -and- Edward E. Neiger, Esq. 60 East 42nd Street, 46th Fl. New York, NY 10165 Telephone: (212) 267-7342 Fax: (212) 918-3427 Counsel for Plaintiff

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