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Red Lobster - Motion Materials

 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.
 
 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.
 
 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").
 
 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.
 
 Supplementary Application Record (Initial Recognition Order) Returnable May 28, 2024
May 24, 2024
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.
 
 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")
 
 Application Record (Interim Stay Order - Foreign Proceedings)
May 20, 2024
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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