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Red Lobster - Motion Materials
 Factum of the Foreign Representative (CCAA Termination Order) |
November 4, 2024 |
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This factum is filed in support of a motion by RL Management in its capacity as the Foreign Representative of itself, RL Hospitality and RL Canada, for an order, among other things: (a) approving the fees, disbursements and activities of FTI in its capacity as Information Officer of the Debtor; and (b) terminating the within proceedings under Part IV of the Companies' Creditors Arrangement Act ("CCAA") and granting related relief including discharging the Information Officer and granting a release in respect of the Information Officer and its counsel. | |
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Motion Record (Termination of CCAA Recognition Proceedings) Returnable November 5, 2024 |
October 25, 2024 |
| Motion Record of the Foreign Representative in connection with a motion seeking, among other things, termination of the CCAA proceeding. This motion is returnable on Tuesday, November 5, 2024 at 11 a.m. via Zoom. | |
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Factum of the Foreign Representative (Third Supplemental Order) Draft Third Supplemental Order (Foreign Main Proceeding) Redline - Draft Third Supplemental Order to Motion Record |
September 9, 2024 |
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This factum is filed in support of a motion by RL Management in its capacity as the Foreign Representative of itself, RL Hospitality and RL Canada, for, among other things: (a) recognizing and giving full force and effect to the following orders of the US Court in the Chapter 11 Cases; (b) ordering that the compromises, arrangements, releases, discharges and injunctions contained and referenced in the Plan and as approved by the Confirmation Order are valid and that, effective on the Plan Effective Date, all such releases, discharges and injunctions are recognized and given full force and effect in all provinces and territories of Canada; (c) authorizing the Canadian Debtors to take such steps and execute such additional documents as may be necessary or desirable for the implementation of the Plan; (d) permanently staying and dismissing all court actions and proceedings commenced against the Canadian Debtors in Canada on a with prejudice and without costs basis as of the Plan Effective Date; and (e) terminating the stay of proceedings and other restrictions on the business of the Canadian Debtors set out in the Supplemental Order (Foreign Main Proceeding) dated May 28, 2024 and Initial Recognition Order (Foreign Main Proceeding) dated May 28, 2024. | |
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Supplementary Motion Record (Confirmation Order Recognition and Ancillary Relief) Returnable September 10, 2024 |
September 6, 2024 |
| The Affidavit of Nancy Thompson sworn in support of the Application of Red Lobster Management LLC in its capacity as Foreign Representative of itself, Red Lobster Canada, Inc. and Red Lobster Hospitality LLC. for, amongst other things, recognition of the Confirmation Order and the Second Amended Plan. | |
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Motion Record (Confirmation Order Recognition and Ancillary Relief) Returnable September 10, 2024 |
September 3, 2024 |
| Motion Record of Red Lobster Management LLC in its capacity as Foreign Representative of itself, Red Lobster Canada, Inc. and Red Lobster Hospitality LLC in support of a motion for recognition of, among other things, an order of the US Court confirming the Joint Chapter 11 Plan. | |
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Supplementary Motion Record (Second Supplemental Order) Returnable June 18, 2024 Factum of the Foreign Representative (Recognition of Second Day Orders and Sale Procedure Order) |
June 17, 2024 |
| Supplementary Motion Record and Factum of Red Lobster Management LLC in its capacity as Foreign Representative of itself, Red Lobster Canada, Inc. and Red Lobster Hospitality LLC in support of a motion for recognition of, among other things, a sale procedure order. | |
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Motion Record (Second Supplemental Order) |
June 11, 2024 |
| Motion Record of Red Lobster Management LLC in its capacity as Foreign Representative of itself, Red Lobster Canada, Inc. and Red Lobster Hospitality LLC in support of a motion for recognition of, among other things, a sale procedure order. The motion is scheduled for Tuesday, June 18, 2024, at 10:00 a.m. via Zoom videoconference. | |
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Factum of the Foreign Representative (Recognition of Foreign Main Proceeding) |
May 27, 2024 |
| This factum is filed in support of an application under Part IV of the CCAA by RL Management in its capacity as the Foreign Representative of itself, RL Hospitality and RL Canada (together with RL Management and RL Hospitality, the "Canadian Debtors"), for, among other things, recognition of proceedings in the United States of America (the "US Proceedings") under the Bankruptcy Code commenced by the Canadian Debtors and certain affiliated entities (collectively, the "Debtors") in the US Court, and recognizing certain orders of the US Court made in the US Proceedings (the "First Day Orders"). | |
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Second Supplementary Application Record (Initial Recognition Order) Returnable May 28, 2024 |
May 26, 2024 |
| The Affidavit of Nancy Thompson sworn in support of the Application of RL Management for, amongst other things, recognition of the Chapter 11 Cases of the Canadian Debtors as foreign main proceedings and for no other purpose. | |
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Supplementary Application Record (Initial Recognition Order) Returnable May 28, 2024 |
May 24, 2024 |
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The Applicant brings this application as the proposed foreign representative of itself and the Canadian Debtors for the following relief pursuant to Part IV of the CCAA and Section 106 of the CJA, as amended: (a) an Interim Stay Order; (b) an Initial Recognition Order; (c) a Supplemental Order; and (d) such further and other relief as counsel may request and this Honourable Court may deem just. | |
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Factum of the Applicant (Application for Interim Stay Order) |
May 20, 2024 |
| This factum is filed in support of an application under Part IV of the Companies' Creditors Arrangement Act (the "CCAA") and section 106 of the Courts of Justice Act (the "CJA") by Red Lobster Management LLC ("RL Management") as the proposed foreign representative of itself, Red Lobster Hospitality LLC ("RL Hospitality") and Red Lobster Canada, Inc. ("RL Canada" and, together with RL Management, the "Canadian Debtors"), for an interim stay of proceedings in connection with proceedings (the "US Proceedings") under Chapter 11 of Title 11 of the United States Code (the "Bankruptcy Code") commenced by RL Management, RL Hospitality and RL Canada, as well as Red Lobster Restaurants LLC, RLSV, Inc., RL Kansas LLC, Red Lobster Sourcing LLC, Red Lobster Supply LLC, RL Columbia LLC, RL of Frederick, Inc., Red Lobster of Texas, Inc., RL Maryland, Inc., Red Lobster of Bel Air, Inc., RL Salisbury LLC and Red Lobster International Holdings LLC (the "Debtors") in the United States Bankruptcy Court for the Middle District of Florida, Orlando Division (the "US Court"). At the First Day Hearing, scheduled for May 21, 2024, the Debtors will seek various first day orders pursuant to the US Code (the "First Day Orders"), including, among other things, an order appointing RL Management as the foreign representative for the Debtors (in such capacity, the "Foreign Representative") | |
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Application Record (Interim Stay Order - Foreign Proceedings) |
May 20, 2024 |
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The Application Record of Red Lobster Management LLC ("RL Management") for, inter alia: (a) The Interim Stay Order; and (b) Such further and other relief as counsel may request and this Honourable Court may deem just. | |
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