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Full title: Motion for Payment of Administrative Expenses/Claims Application of Gordon Food Service, Inc. for Allowance and Payment of Administrative Priority Claim. Filed by Gordon Food Service, Inc.. Hearing scheduled for 12/2/2021 at 10:00 AM at US Bankruptcy Court, 824 Market St., 6th Fl., Courtroom #3, Wilmington, Delaware. Objections due by 11/24/2021. (Attachments: # (1) Exhibit A # (2) Proposed Form of Order # (3) Notice # (4) Certificate of Service) (Werkheiser, Gregory)

Document posted on Nov 16, 2021 in the bankruptcy, 5 pages and 0 tables.

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Practice and Procedure of the United States Bankruptcy Court for the District of Delaware, GFS consents to the entry of a final order by the Court in connection with this Application to the extent that it is later determined that the Court, absent consent of the parties, cannot enter final orders or judgments consistent with Article III of the United States Constitution.On October 14, 2021 (the “Petition Date”), Gulf Coast Health Care, LLC (“Gulf Coast”) and sixty-one affiliated companies (collectively, the “Debtors”) filed voluntary petitions for relief under Chapter 11 of the Bankruptcy Code.Within the 20-day period preceding the Petition Date, Gulf Coast and the following Debtors (collectively with Gulf Coast, the “20-Day Debtors”) received goods from GFS (the “20-Day Goods”) totaling the following amounts: Debtor Location Amount MS Singing LLC Singing River Health and Rehabilitation Center $41,018.58 De Luna Health and Rehabilitation Center $35,343.51 Total $329,132.61 Pursuant to section 503(b)(9), GFS is entitled to an administrative priority claim against the estate of Gulf Coast an administrative claim totaling $329,132.61, and an administrative priority claim against each of the other 20-Day Debtors in the amounts listed above (the “503(b)(9) Claims”).For sake of clarity, GFS only seeks a single satisfaction for the amounts it is due, even though it is entitled to administrative priority claims jointly against Gulf Coast with each of the other Debtor operating entities Gulf Cost conducted business with.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 GULF COAST HEALTH Case No. 21-11336 (KBO) CARE, LLC, et al.,1 Jointly Administered Debtors. Hearing Date: Dec. 2, 2021, at 10:00 a.m. (ET) Objection Deadline: Nov. 24, 2021 APPLICATION OF GORDON FOOD SERVICE, INC. FOR ALLOWANCE AND PAYMENT OF ADMINISTRATIVE PRIORITY CLAIM Gordon Food Service, Inc. (“GFS”), by its undersigned counsel, hereby submits the following Application for Allowance and Payment of Administrative Priority Claim pursuant to 11 U.S.C. § 503(b)(9) (the “Application”). In support of its Application, GFS respectfully states as follows: JURISDICTION, VENUE AND RELATED MATTERS 1. This Court has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Amended Standing Order of Reference from the United States District Court for the District of Delaware dated as of February 29, 2012. Venue is proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). 2. The statutory bases for the relief requested herein are sections 105 and 503 of Title 11 of the United States Code (as amended, the “Bankruptcy Code”). 1 The last four digits of Gulf Coast Health Care, LLC’s federal tax identification number are 9281. There are 62 Debtors in these chapter 11 cases, which cases are being jointly administered. A complete list of the Debtors and the last four digits of their federal tax identification numbers are not provided herein. A complete list of such information may be obtained on the website of the Debtors’ claims and noticing agent at https://dm.epiq11.com/GulfCoastHealthCare. The location of Gulf Coast Health Care, LLC’s corporate headquarters and the Debtors’ service address is 9511 Holsberry Lane, Suite B11, Pensacola, FL 32534.

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3. Pursuant to Rule 9013-1(f) of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware, GFS consents to the entry of a final order by the Court in connection with this Application to the extent that it is later determined that the Court, absent consent of the parties, cannot enter final orders or judgments consistent with Article III of the United States Constitution. BACKGROUND 4. On October 14, 2021 (the “Petition Date”), Gulf Coast Health Care, LLC (“Gulf Coast”) and sixty-one affiliated companies (collectively, the “Debtors”) filed voluntary petitions for relief under Chapter 11 of the Bankruptcy Code. The Debtors are currently operating as debtors-in-possession. 5. Gulf Coast jointly operates with certain other Debtors various skilled nursing, assisted living, and long-term care centers throughout Florida, Georgia, and Mississippi. 6. Before the Petition Date, Gulf Coast (with certain of the Debtors) ordered from GFS and GFS shipped to Gulf Coast (and those certain Debtors) various foodservice goods. Within the 20-day period preceding the Petition Date, Gulf Coast and the following Debtors (collectively with Gulf Coast, the “20-Day Debtors”) received goods from GFS (the “20-Day Goods”) totaling the following amounts: Debtor Location Amount MS Singing LLC Singing River Health and Rehabilitation Center $41,018.58 MS HUD Boyington LLC The Boyington Health and Rehabilitation Center $92,002.54 NF Escambia LLC Olive Branch Health and Rehabilitation Center $77,258.40 Brevard Oaks Center LLC Viera del Mar Health and Rehabilitation Center $35,514.11 SF Brevard, LLC The Rehabilitation Center of Lake City $27,825.06 SC-GA2018 Cobblestone Cobblestone Rehabilitation and Health Center $20,170.41 Rehabilitation and Healthcare Center, LLC NF Nine Mile, LLC De Luna Health and Rehabilitation Center $35,343.51 Total $329,132.61

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Pursuant to section 503(b)(9), GFS is entitled to an administrative priority claim against the estate of Gulf Coast an administrative claim totaling $329,132.61, and an administrative priority claim against each of the other 20-Day Debtors in the amounts listed above (the “503(b)(9) Claims”). REQUEST FOR ALLOWANCE AND PAYMENT 7. By this Application, GFS seeks an Order from the Court allowing GFS administrative claims against the 20-Day Debtors’ estates for the value of the 20-Day Goods delivered to the 20-Day Debtors. A summary of the invoices for the goods received by the 20-Day Debtors are attached hereto as Exhibit A.2 8. Section 503(b)(9) of the Bankruptcy Code states “after notice and a hearing, there shall be allowed administrative expenses” for “the value of any goods received by the debtor within 20 days before the date of commencement of a case under this title in which the goods have been sold to the debtor in the ordinary course of such debtor’s business.” 11 U.S.C. § 503(b)(9). 9. The 20-Day Debtors received the 20-Day Goods within 20 days of the Petition Date. The 20-Day Goods were sold to the 20-Day Debtors by GFS in the ordinary course of the Debtors’ business. In addition, GFS has not received payment for the 20-Day Goods. Accordingly, pursuant to section 503(b)(9), GFS is entitled to administrative claims for the value of the 20-Day Goods provided to each of the 20-Day Debtors. 10. As administrative claims, the 503(b)(9) Claims are entitled to priority in any distribution from assets of the 20-Day Debtors’ estates. 11 U.S.C. § 507(a)(2). This priority is secondary only to domestic support claims. 11 U.S.C. § 507(a)(1). The 503(b)(9) Claims must be paid in full and in cash in order for the Court to confirm any plan of reorganization. 11 U.S.C. § 1129(a)(9)(A). Additionally, as Section 503 does not specifically address when 2 The invoices are too voluminous to attach but can be made available to the Court upon request and to other parties in interest upon reasonable request.

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administrative claims will be paid in a Chapter 11 case, most courts interpreting these provisions have held that the bankruptcy court has discretion to order that such claims be paid at any time during the pendency of the case, but no later than confirmation. See, e.g., In re Global Home Products, LLC, Case No. 06-10340 (KG), 2006 WL 3791955 at *3 (Bankr. D. Del. Dec. 21, 2006); In re Garden Ridge Corp., 323 B.R. 136, 143 (Bankr. D. Del. 2005) (citations omitted). Accordingly, GFS requests that its 503(b)(9) Claims be paid at the earliest date and at the same percentage as any other allowed administrative claims of equal priority against the Debtors’ estates. 11. This Application is made without prejudice to, and GFS reserves, all other rights, claims, demands, and remedies available to GFS, at law or in equity. In addition, GFS reserves the right to seek payment of further amounts under section 503(b)(9) if it later discovers information that additional goods were received by the Debtors within 20 days of the Petition Date. By seeking recovery from Gulf Coast and each of the other Debtors it jointly conducts business with, GFS is not seeking a double recovery. For sake of clarity, GFS only seeks a single satisfaction for the amounts it is due, even though it is entitled to administrative priority claims jointly against Gulf Coast with each of the other Debtor operating entities Gulf Cost conducted business with. [CONTINUED NEXT PAGE]

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WHEREFORE, having satisfied the requirements of section 503(b)(9), GFS requests that this Court enter an order: (1) allowing the 503(b)(9) Claims; (2) directing that distributions on the 503(b)(9) Claims be made at the earliest date and at the same percentage as any other allowed administrative claims of equal priority against the 20-Day Debtors’ estates; and (3) for such other and further relief as this Court deems just and proper. Dated: November 17, 2021 BENESCH, FRIEDLANDER, COPLAN & Wilmington, Delaware ARONOFF LLP /s/ Gregory W. Werkheiser Gregory W. Werkheiser (DE #3553) 1313 N. Market Street, Suite 1201 Wilmington, Delaware 19801 Telephone: (302) 442-7010 Facsimile: (302) 442-7012 Email: gwerkheiser@beneschlaw.com -and- Jason M. Torf, Esq. ICE MILLER LLP 200 W. Madison Street, Suite 3500 Chicago, IL 60606 Telephone: (312) 726-6244 Facsimile: (312) 726-6214 Email: jason.torf@icemiller.com -and- John C. Cannizzaro, Esq. ICE MILLER LLP 250 West Street, Suite 700 Columbus, OH 43215 Telephone: (614) 462-1070 Facsimile: (614) 232-6923 Email: john.cannizzaro@icemiller.com Counsel to Gordon Food Service, Inc.

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