Case 16-11242-BLS Doc 449 Filed 09/29/16 Page 1 of 11 FOR ... · RIT LLC, filed its petition. On June 17, 2016, Debtor Phoenix Brands Canada Laundry LLC filed its petition. 6. Pursuant

UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE

) In re: )

)

PHOENIX BRANDS LLC, et al,' )

) Debtors. )

)

Chapter 11

Case No. 16-11242 (BLS)

(Jointly Administered) Re: DJ. 433 Hearing Date: October 20, 2016 @ 11:00 a.m. Obj. Deadline: September 29, 2016 @4:00 p.m.

OBJECTION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS TO

DEBTORS' MOTION FOR AN ORDER EXTENDING THEIR EXCLUSIVE PERIODS

TO FILE A CHAPTER 11 PLAN AND SOLICIT ACCEPTANCES THEREOF

The Official Committee of Unsecured Creditors (the "Committee") of the above-

captioned debtors and debtors-in-possession (the "Debtors"), by and through its counsel, Saul

Ewing LLP, hereby objects (the "Objection") to the Debtors' Motion for an Order Extending

Their Exclusive Periods to File a Chapter 11 Plan and Solicit Acceptances Thereof [D.I. 433]

(the "Motion"), 2 and in support of the Objection, respectfully states as follows:

PRELIMINARY STATEMENT

1. The Debtors seek a 120-day extension of the exclusive period to file a chapter 11

plan (the "Exclusive Filing Period"), through and including January 14, 2017. In the

Committee's view, this request is completely inappropriate. As of August 8, 2016, the Debtors

have closed on all three of their asset sales. The Debtors have fully performed under one of their

transition services agreements ("TSA"), and the initial terms of the other two TSAs expire in

early October, 2016. Other than performance under the TSAs, the Debtors have no remaining

operations.

2

The Debtors, together with the last four digits of each Debtor's tax identification number, are: Phoenix

Brands LLC, (4609), Phoenix Brands Parent LLC, (8729), Phoenix North LLC, (no EIN), Phoenix Brands Canada ULC (a Nova Scotia Company), Phoenix Brands Canada Laundry LLC (no EIN), and Phoenix RIT LLC (5149). The address of each of the Debtors is 1 Landmark Square, Suite 1810, Stamford, CT 06901, except Phoenix Brands Canada ULC, which is Box 50, 1 First Canadian Place, Toronto, Ontario, Canada

M5X 1B8.

Capitalized terms not otherwise defined herein shall have the same meaning as set forth in the Motion.

655663.5 09128/2016

Case 16-11242-BLS Doc 449 Filed 09/29/16 Page 1 of 11

2. There are no exotic issues to be dealt with through the liquidating plan in these

cases, certainly not that would justify a 120-day extension. These estates are ripe for "pot plan"

with an analyses of whether there should be some form of substantive consolidation, which

requires some claim analysis but should not be unduly time consuming. In no event should the

remaining tasks here take four months and since tasks tend to take the time allotted, this runs the

risk of unneeded delay, cost, and an erosion of creditor recoveries. The Debtors cannot credibly

claim to need an additional 120 days to propose a "pot plan."

3. Recognizing the benefit for speed at the July 18, 2016 sale hearing, the Debtors

represented to the Court and the Committee that their goal was to confirm a plan coterminous

with the TSAs.

4. Given the cost of administration necessitated by delay, the Committee does not

believe it is in the creditors' best interest to continue to allow the Debtors to have exclusive

control over the plan process for an additional 120 days. Because the Debtors cannot

demonstrate sufficient cause for the requested extension of the Exclusive Filing Period, the

Committee respectfully requests that the Debtors should, at most, be given only a 60-day

extension. If more time is needed after that 60-day extension and there is no consent, the parties

should have to return to Court to consider why and whether exclusivity should be terminated to

allow the Committee to move forward.

BACKGROUND

I. The Bankruptcy Cases

5. On May 19, 2016, Debtors Phoenix Brands LLC, Phoenix Brands Parent LLC,

Phoenix North LLC, and Phoenix Canada ULC commenced their cases by filing voluntary

petitions for relief under chapter 11 of the Bankruptcy Code. On June 1, 2016, Debtor Phoenix

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2


RIT LLC, filed its petition. On June 17, 2016, Debtor Phoenix Brands Canada Laundry LLC

filed its petition.

6. Pursuant to the Order Authorizing Joint Administration of Related Chapter 11

Cases for Procedural Purposes Only [D.I. 44], the Order (A) Authorizing Joint Administration

of Related Chapter 11 Cases for Procedural Purposes Only and (B) Applying Certain Orders in

the Chapter 11 Cases of Phoenix Brands LLC and its Affiliated Debtors to the Chapter 11 Case

of Phoenix RIT LLC [D.I. 127], and the Order (A) Directing Joint Administration of Related

Chapter 11 Cases for Procedural Purposes Only and (B) Applying Certain Orders in the

Chapter 11 Cases of Phoenix Brands LLC and its Affiliated Debtors to the Chapter 11 Case of

Phoenix Brands Canada Laundry, LLC [D.I. 255], the chapter 11 cases of the Debtors are jointly

administered and are consolidated for procedural purposes.

7. The Debtors continue in possession of their properties and continue to operate and

manage their businesses as debtors-in-possession pursuant to sections 1107(a) and 1108 of the

Bankruptcy Code. No request for the appointment of a trustee or examiner has been made in

these chapter 11 cases.

8. On June 1, 2016, the Office of the United States Trustee appointed the Committee

pursuant to section 1102(a)(1) of the Bankruptcy Code [D.I. 94].

9. On July 18, 2016, this Court entered the following orders approving three sales of

the Debtors' assets: an order [D.I. 283] approving the sale of the Debtors' "Canadian Laundry"

assets to Lavo, Inc. ("Lavo"), an order [D.I. 284] approving the sale of the Debtors' "US

Laundry" assets to U.S. Nonwovens Corporation ("US Nonwovens"), and an order [D.I. 285]

approving the sale of the Debtors "RIT" assets to Nakoma Products, LLC ("Nakoma"). On

August 1, 2016, the Debtors' sale of the RIT assets closed, on August 2, 2016, the sale of the

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Debtors' Canadian Laundry assets closed, and on August 8, 2016, the sale of the Debtors' US

Laundry assets closed.

10. In each of the asset sales, the Debtors and the respective purchaser entered into a

TSA. The Lavo TSA terminated September 1, 2016. The last day of the initial term of the U.S.

Nonwovens TSA is October 1, 2016, and the last day of the initial term of the Nakoma TSA is

October 7, 2016. 3

II. The Plan Process and the Motion

11. After the sales closed, the Committee immediately focused on getting these cases

through plan confirmation. The Committee saw these cases as the perfect candidates for a

combined plan and disclosure statement process, as contemplated under this Court's local rules.

12. The Committee was pleased when the Court raised this issue sua sponte at the

July 18, 2016 sale hearing, and was optimistic when, in response, the Debtors represented to the

Court that the Debtors intended to propose a plan for confirmation "at or around" the time of the

expiration of the TSAs in early October 2016:

THE COURT: Let me ask you another question.

DEBTORS' COUNSEL: Yes, Your Honor.

THE COURT: And I don't want to get too far down the lane; I think we

may have had a discussion about this. It's been -- it has become my practice in

sale cases to at least ask the debtor, at the approval of the sale, where you're going

from here. I do understand that there are some additional assets, and I do

understand that there are claims and -- there's process left to this. I'm sure Ms.

Jones has told you that my strong preference —

And, Ms. Levine, you've heard this speech too.

-- is that we move rapidly if circumstances warrant -- and I trust your

judgment in this respect -- but to move forward to a confirmed plan, in a format

that would allow, frankly, all stakeholders to achieve and retain the benefit of the

Both the U.S. Nonwovens TSA and the Nakoma TSA provide an option to extend the initial term, but as of

the date hereof, the Debtors have not provided any written notice to the Committee showing that those

TSAs have been extended.

655663.5 09/28/2016

4


productive sale process that's occurred. And I have on many occasions combined disclosure statement and plan. Again, I don't know what the facts are, so if this is

not a case that merits that, then so be it and I'll be guided by the parties. But if

the parties are prepared to move forward promptly, you can fully expect that I will

be a partner in that exercise, with respect to scheduling and moving the matter

forward.

DEBTORS COUNSEL: We appreciate that, Your Honor, and it is our

expectation and intention, working with the committee, to craft a plan shortly and to bring that plan on for confirmation at or around the expiration of the

transition-services agreement.

THE COURT: Terrific, Okay.

Transcript of Proceedings at 55-56, In re Phoenix Brands, LLC, et al., No. 16-11242 (July 18,

2016) (emphasis added).

13. After the July 18, 2016 sale hearing, the Committee urged the Debtors to quickly

move forward with a combined plan and disclosure statement. The Committee raised the issue at

the August 9, 2016 hearing:

COMMITTEE'S COUNSEL: [W]e're hoping to move quickly through

plan and disclosure statement, if some of the -- and we heard Your Honor say

there's a possibility that you would think kindly of a combined plan and

disclosure statement, so it's just a —

THE COURT: You heard me say it before.

COMMITTEE'S COUNSEL: -- pot of money.

Transcript of Proceedings at 9, In re Phoenix Brands, LLC, et al., No. 16-11242 (August 9,

2016) (emphasis added).

14. At that August 8, 2016 hearing, the Debtors repeated their intention to pursue a

combined plan and disclosure statement process, with confirmation to occur at or near the

expiration of the TSAs (i.e., early October 2016):

DEBTORS' COUNSEL: So with the sales done, the TSAs now in process,

the employee-plan motion about to be filed, that leaves us just with the plan of

reorganization.

THE COURT: Um-hum.

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5


DEBTORS' COUNSEL: We've already started initial conversations with

the committee, about what the shape of a plan is going to look like. As Ms.

Levine said and the debtors support, we're going to try to accomplish this through

a combined plan and disclosure statement so that we can save the estate time and

money. And also –

THE COURT: Um-hum.

DEBTORS' COUNSEL: -- I think time is of the essence here. We have a

sixty-day window. It would be -- while aspirational, I think we would love to be

before Your Honor at some point towards the end of that window, on

confirmation, if we can get there, so that the plan is coterminous with the TSA.

And we can shift whatever post-TSA operations and post-TSA workouts can be

done, to whatever entity is going to survive, whatever plan that we get to.

Id. at 11-12 (emphasis added). And the Court commented:

THE COURT: But again, to me, the goal here is -- and I hear it loud and

clear from Ms. Levine – is preserving as much value for distribution to

stakeholders as possible. And getting out of bankruptcy is -- time is money in

these cases. And there's just a big difference between being in for two months and

being in for four months.

Id. at 14.

15. After the last asset sale closed on August 8, 2016, the Committee again urged the

Debtors to quickly move these cases toward confirmation. On August 12, 2016, the Debtors

represented to the Committee that they had begun drafting the plan and disclosure statement. In

the weeks since that representation, the Committee has regularly followed up with the Debtors

on plan issues, but the Debtors have not yet provided a draft plan.

16. Compounding the Committee's frustration is the inappropriately broad relief

requested in the Motion, which seeks to extend the Debtors' exclusive right to file a plan to

January 14, 2017, and to extend the period to solicit votes to March 15, 2017. Contrary to the

Debtors' prior representations to the Committee and the Court—that they will seek to confirm a

plan in the fall of 2016—the Debtors are now, through the Motion, looking to push confirmation

back until winter or spring 2017.

655663.5 09/28/2016

6


OBJECTION

17. The Bankruptcy Code affords a debtor an exclusive 120-day period within which

to propose a chapter 11 plan. 11 U.S.C. § 1121(b). Under section 1121(d), a bankruptcy court

may increase the debtor's exclusivity period beyond the initial 120 days, but only "for cause."

11 U.S.C. § 1121(d); see also First Am. Bank of N.Y. v. Southwest Gloves & Safety Equip., Inc.,

64 B.R. 963, 965 (D. Del. 1986) (section 1121(d) allows the bankruptcy court flexibility to

reduce or extend exclusivity). The Bankruptcy Code does not define "cause," but the legislative

history, as amplified by decisional authority, indicates that the following nine factors are relevant

to the determination of whether exclusivity should be extended:

(1) the size and complexity of the case; (2) the necessity for sufficient

time to permit the debtor to negotiate a plan of reorganization and

prepare adequate information; (3) the existence of good faith progress

toward reorganization; (4) the fact that the debtor is paying its bills as

they become due; (5) whether the debtor has demonstrated reasonable

prospects for filing a viable plan; (6) whether the debtor has made

progress in negotiations with its creditors; (7) the amount of time which

has elapsed in the case; (8) whether the debtor is seeking an extension

of exclusivity in order to pressure creditors to submit to the debtor's

reorganization demands; and (9) whether an unresolved contingency

exists.

In re Borders Group, Inc., 460 B.R. 818, 822 (Bankr. S.D.N.Y. 2011) (citing In re Adelphia

Communs. Corp., 352 B.R. 578, 587 (Bankr. S.D.N.Y. 2006)).

18. The legislative history also demonstrates that Congress disfavors "undue

extension[s]" that result in "excessively prolonged and costly delay, to the detriment of

creditors." See H.R. Rep. No. 103-835, at 36 (1994), reprinted in 1994 U.S.C.C.A.N. 3340,

3344 (1994); see also Bankruptcy Amendments Act of 1994: Hearing on S. 540 Before Subcomm.

on Econ. and Comm. and the Comm. of the Judiciary, 103rd Cong. (Aug. 17, 1994) (statement of

Philip S. Corwin, Director & Counsel, Am. Bankers Assoc.) ("We believe that in too many cases

the courts have abused their discretion under [the 'for cause'] standard and have been too lenient

655663.5 09/28/2016

7


in granting extensions of exclusivity. . . ."). In fact, "both the language and the purpose of

[section 1121(d)] require that an extension not be granted routinely." In re Pine Run Trust, Inc.,

67 B.R. 432, 434 (Bankr. E.D. Pa. 1986); see United Say. Ass 'n v. Timbers of Inwood Forest

Assocs., Ltd. (In re Timber of Inwood Forest Assocs., Ltd.), 808 F.2d 363, 372 (5th Cir. 1987),

aff'd, 484 U.S. 365 (1988) ("Section 1121 was designed, and should be faithfully interpreted, to

limit the delay that makes creditors the hostages of Chapter 11 debtors."); In re Curry Corp., 148

B.R. 754, 755-56 (Bankr. S.D.N.Y. 1992) (holding that courts should not "routinely extend the

exclusive period" upon creditor objection).

19. While the determination as to whether "cause" exists is left to the discretion of the

bankruptcy court, that discretion is "limited by the requirement that cause be shown." In re

Perkins, 71 B.R. 294, 298 (W.D. Tenn. 1987). The debtor bears the burden of proving that

"cause" exists. See, e.g., In re Newark Airport/Hotel Limited Partnership, 156 B.R. 444, 451

(Bankr. D.N.J. 1993). And, even if "cause" exists, a bankruptcy court may still deny an

extension of exclusivity in cases where, for example, "the debtor has delayed in arriving at an

agreement or is attempting to pressure other parties to yield to a position which is necessarily

prejudicial." In re Sharon Steel Corp., 78 B.R. 762, 765 (Bankr. W.D. Pa. 1987).

20. Given the cost of administration and delay, the Committee does not believe it is in

the creditors' best interest to continue to allow the Debtors to have exclusive control over the

plan process for the time period requested. The Debtors have made no measurable progress

toward a plan since the closings of the sales, and should only be given—at most—a 60-day

extension, rather than the requested 120 days. Because the Debtors cannot demonstrate

sufficient cause for the requested extension of the Exclusive Filing Period, the Committee

respectfully requests that the Motion be denied.

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8


21. The relevant factors weigh against granting the Debtors' Motion. First, these

cases are not large or complex, certainly not large or complex enough to justify the requested

extension. There are no exotic issues to negotiate in a plan. All that remains are normal, "run of

the mill" issues that arise in any chapter 11 case.

22. Second, the Debtors have had more than sufficient time to attempt to propose a

plan of liquidation—or at the very least, outline the basic terms of a plan to the Committee—and

have not done so. The Debtors need only to complete performance under the TSAs, allocate the

purchase price, analyze the limited number of claims asserted against the Debtors' estates (only

116 proofs of claim, many of them duplicative, were filed by the bar date), and estimate a

proposed distribution to holders of allowed general unsecured claims. Accordingly, there is no

need to permit the Debtors any more time to prepare a plan of liquidation.

23. As to the third factor (good faith progress toward reorganization or, in this case,

liquidation), the Debtors have done very little to move the plan process forward. The Debtors

should, at most, be given a brief 60-day extension, and if no progress is made by then, the

Debtors should hand off the plan process to the Committee. This factor is particularly compelling

when it is the Committee's constituents who are awaiting payment and who are footing the bill

for the costs of administration of these cases.

24. The fourth factor (a debtor paying its bills as they come due) is largely irrelevant,

as the Debtors, after expiration of the remaining two TSAs, will no longer be running an

operating business.

25. The fifth (reasonable prospects for filing a viable plan) and sixth (progress in

negotiations with creditors) factors, taken together, both weigh against a long extension of

exclusivity. The Debtors have not proposed a plan to the Committee or to any other constituency

and, therefore, their prospects for pursuing a viable plan are unknown. The Committee is

655663.5 09/2812016

9


confident, however, that a simple, straight-forward plan of liquidation will win the support of

creditors. While the Debtors have engaged in some negotiations with the Committee, it is

noteworthy that those discussions have been very preliminary, and only came after the

Committee repeatedly hounded the Debtors to engage.

26. The seventh factor (amount of time elapsed in case) favors denial of an extension.

The Debtors have not made any measurable progress toward a plan since the sale closings, and

the requested extension will serve only to further delay the conclusion of these cases.

27. The eighth factor (whether the extension is designed to pressure creditors to

submit to a debtor's demands) is not applicable, as the Debtors have not proposed a plan.

28. Finally, there are no significant "unresolved contingencies" in these cases. The

Committee believes there are no real obstacles to confirming a plan. Any remaining issues in

these cases can and will be addressed post-confirmation.

CONCLUSION

29. The Debtors have had more than enough time to move the plan process along.

They have not done so. The Committee has done everything in its power to move, the plan

process forward and is ready to proceed with a combined plan and disclosure statement process.

The Committee cannot sit back and allow these cases to languish any longer.

30. The Debtors cannot demonstrate sufficient "cause" to warrant the requested

extension of the Exclusive Filing Period, as all of the applicable factors weigh against a finding

of "cause." The Debtors should be given a brief extension, nothing more.

655663.5 09/28/2016

1 0


SAUL EWING LLP

WHEREFORE, the Committee respectfully requests that the Court (i) sustain its

Objection; (ii) deny the Motion; and (iii) grant such other and further relief as may be just and

proper.

Dated: September 29, 2016

By: M Minu (DE Ba il o. 659)

Lucian B. Murley (DE Bar No. 4892)

1201 North Market Street, Suite 2300

P.O. Box 1266 Wilmington, DE 19899

Telephone: (302) 421-6840

Facsimile: (302) 421-5873

[email protected]

[email protected]

-and-

Sharon L. Levine

Dipesh Patel One Riverfront Plaza 1037 Raymond Blvd., Suite 1520

Newark, NJ 07102-5426

Telephone: (973) 286-6713

Facsimile: (973) 286-6821

[email protected]

[email protected]

Counsel to the Official Committee of Unsecured Creditors of Phoenix Brands LLC, et al.

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11


UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE

) Chapter 11

In re: ) Case No. 16-11242 (BLS)

PHOENIX BRANDS LLC, et al.,

) (Jointly Administered)

Debtors.

CERTIFICATE OF SERVICE

I, Lucian B. Murley, hereby certify that on September 29, 2016, I caused a copy of the

Objection of the Official Committee of Unsecured Creditors to Debtors' Motion for an

Order Extending Their Exclusive Periods to File a Chapter 11 Plan and Solicit Acceptances

Thereof to be served on the parties on the attached service list in the manner indicated therein.

SAUL EWING LLP

By:

.V rley (1 Bar No. 4892)

1201 North Market Street, Suite 2300

P. 0. Box 1266 Wilmington, DE 19899

(302) 421-6898

Dated: September 29, 2016

6556615 9/28/16

Case 16-11242-BLS Doc 449-1 Filed 09/29/16 Page 1 of 3

PHOENIX BRANDS LLC, et al.

Service List

Via Hand Delivery:

Laura Davis Jones, Esquire

Joseph M. Mulvihill, Esquire

Pachulski Stang Ziehl & Jones LLP

919 N. Market Street, 17th Floor

P.O. Box 8705

Wilmington, DE 19899-8705

Hannah McCollum, Esquire

Office of the United States Trustee

for the District of Delaware

J. Caleb Boggs Federal Building

844 King Street, Suite 2007

Wilmington, DE 19801

Robert Dehney, Esquire

Curtis Miller, Esquire

Morris, Nichols, Arsht & Tunnell LLP

1201 N. Market Street, 16th Floor

P.O. Box 1347


Via Electronic Mail and

First Class Mail: Joseph T. Moldovan, Esquire

Robert K. Dakis, Esquire

MoiTison Cohen LLP

909 Third Avenue

New York, NY 10022

Dimitri Karcazes, Esquire

Zach Garrett, Esquire

Goldberg Kohn Ltd.

55 E. Monroe, Suite 3300

Chicago, IL 60603

Via First Class Mail: Phoenix Brands LLC, et al.

Attn: Bill Littlefield

1 Landmark Square #18

Stamford, CT 06901

Madison Capital Funding Attn: James Powell and Kevin Bolash

30 S. Wacker Drive, Suite 3700

Chicago, IL 60606

Fifth Street Asset Management Inc.

Attn: Brian Finkelstein, Michael Shannon,

and Irene Chen 777 W. Putnam Avenue, 3rd Floor

Greenwich, CT 06830

Jeremy W. Ryan, Esquire

R. Stephen McNeill, Esquire

Potter Anderson & Corroon LLP 1313 N. Market Street, 6th Floor

P.O. Box 951 Wilmington, DE 19801

David M. Klauder, Esquire

Bielli & Klauder, LLC

1204 N. King Street


Domenic E. Pacitti, Esquire

Klehr Harrison Harvey Branzburg LLP

919 Market Street, Suite 1000


Rachel B. Mersky, Esquire Monzack Mersky McLaughlin & Browder

1201 N. Orange Street, Suite 400


Joseph H. Huston, Jr., Esquire

Stevens & Lee, P.C. 919 N. Market Street, Suite 1300


655663.5 09/28/2016


Michael J. Barrie, Esquire

Kevin M. Capuzzi, Esquire

Benesch, Friedlander, CopIan

& Aronoff LLP

222 Delaware Avenue, Suite 801


Ellen Slights, Esquire

U.S. Attorney's Office

1007 N. Orange Street, Suite 700

P.O. Box 2046


John T. Weber, Esquire

Kirkland & Ellis LLP

601 Lexington Avenue

New York, NY 10022-4611

Morton R. Branzburg, Esquire

Klehr Harrison Harvey Branzburg LLP

1835 Market Street

Philadelphia, PA 19103

Vadim J. Rubinstein, Esquire

Loeb & Loeb

345 Park Avenue

New York, NY 10154

Christopher Kelly, Esquire

Karl Block, Esquire

Loeb & Loeb 10100 Santa Monica Blvd.

Los Angeles, CA 90067

Kenneth Rosen, Esquire

Paul Kizel, Esquire

Nicole M. Brown, Esquire

Lowenstein Sandler LLP

65 Livingston Avenue

Roseland, NJ 07068

Vicente Matias Murrell, Esquire Pension Benefit Guaranty Corporation

Office of the Chief Counsel

1200 K Street, N.W.

Washington, D.C. 20005-4026

Edmond O'Brien, Esquire Stempel Bennett Claman & Hochberg, PC

675 Third Avenue, 31st Floor

New York, NY 10017

Jeffrey W. Levitan, Esquire

Scott K. Rutsky, Esquire

Proskauer Rose LLP

Eleven Times Square

New York, NY 10036

Lincolnshire Management, Inc.

Attn: President or Legal Department

780 Third Avenue, 40th Floor

New York, NY 10017

Akzo Nobel Surface Chemistry LLC

Attn: Keith Porapaiboon

525 W. Van Buren

Chicago, IL 60640

Berry Plastics Corporation

Attn: Tammy Alstadt

101 Oakley Street

Evansville, IN 47710

DS Containers, Inc.

Attn: Mark J. Baiocchi

1789 Hubbard Avenue

Batavia, IL 60510

International Paper

Attn: Mark Wilkund 1740 International Drive

Memphis, TN 38197

XPO Logistics Worldwide, LLC

Attn: Richard EF Valitutto

4035 Piedmont Pkwy

High Point, NC 27265

Internal Revenue Service Centralized Insolvency Operation

P.O. Box 7346 Philadelphia, PA 19101-7346

655663.5 09/28/2016

2


Documents

Case 16-11242-BLS Doc 449 Filed 09/29/16 Page 1 of 11 FOR ... · RIT LLC, filed its petition. On June 17, 2016, Debtor Phoenix Brands Canada Laundry LLC filed its petition. 6. Pursuant