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Full title: Certificate of No Objection Regarding Liquidating Trustee's Third Motion to Extend the Claims Objection Deadline (related document(s)[1571]) Filed by FI Liquidating Trust. (Attachments: # (1) Exhibit A (Proposed Order)) (Johnson, Ericka)

Document posted on Oct 19, 2021 in the bankruptcy, 2 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

The undersigned certifies that the Court’s docket in these cases reflects that no answer, objection, or other responsive pleading to the Motion has been filed.Pursuant to the notice appended to the Motion, objections or responses to the Motion were to be filed and served no later than October 18, 2021 at 4:00 p.m. (prevailing Eastern Time).A hearing on the Motion is scheduled for October 25, 2021 at 10:00 a.m. (prevailing Eastern Time).Accordingly, the undersigned respectfully requests that the Court enter the proposed form of order attached hereto as Exhibit A, which is identical to the proposed form of order attached to the Motion.Stores of Tennessee, Inc. (9888); Fred’s Inc. (4010); 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).

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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 ) ) Related Docket No.: 1571 CERTIFICATE OF NO OBJECTION REGARDING LIQUIDATING TRUSTEE’S THIRD MOTION TO EXTEND THE CLAIMS OBJECTION DEADLINE The undersigned hereby certifies that no answer, objection, or other responsive pleading has been received with respect to the Liquidating Trustee’s Third Motion to Extend the Claims Objection Deadline [Docket No. 1571] (the “Motion”) filed on October 4, 2021. The undersigned certifies that the Court’s docket in these cases reflects that no answer, objection, or other responsive pleading to the Motion has been filed. Pursuant to the notice appended to the Motion, objections or responses to the Motion were to be filed and served no later than October 18, 2021 at 4:00 p.m. (prevailing Eastern Time). A hearing on the Motion is scheduled for October 25, 2021 at 10:00 a.m. (prevailing Eastern Time). Accordingly, the undersigned respectfully requests that the Court enter the proposed form of order attached hereto as Exhibit A, which is identical to the proposed form of order attached to 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 Stores of Tennessee, Inc. (9888); Fred’s Inc. (4010); 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’ address is 6625 Lenox Park, Suite 200, Memphis, TN 38115.

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Dated: October 20, 2021 WOMBLE BOND DICKINSON (US) LLP Wilmington, Delaware /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 E-mail: ericka.johnson@wbd-us.com -and- LOWENSTEIN SANDLER LLP Jeffrey L. Cohen, Esq. (admitted pro hac vice) Lindsay H. Sklar, Esq. (admitted pro hac vice) 1251 Avenue of the Americas New York, New York 10020 Telephone: (212) 262-6700 Facsimile: (212) 262-7402 Email: jcohen@lowenstein.com Email: lsklar@lowenstein.com Nicole Fulfree, Esq. (admitted pro hac vice) Colleen Maker, Esq. (admitted pro hac vice) Jeremy Merkin, Esq. (admitted pro hac vice) One Lowenstein Drive Roseland, New Jersey 07068 Telephone: (973) 597-2502 Facsimile: (973) 597-2400 Email: nfulfree@lowenstein.com Email: cmaker@lowenstein.com Email: jmerkin@lowenstein.com Co-Counsel to the Liquidating Trustee and the FI Liquidating Trust

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