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61893/0001-40341478v1
COLE SCHOTZ P.C.Court Plaza North
25 Main Street
P.O. Box 800
Hackensack, New Jersey 07602-0800
(201) 489-3000
(201) 489-1536 Facsimile
Michael D. Sirota ([email protected])
Felice R. Yudkin ([email protected])
Jacob S. Frumkin ([email protected])
Matteo Percontino ([email protected])
Rebecca W. Hollander ([email protected])
Attorneys for Debtorsand Debtors in Possession
UNITED STATES BANKRUPTCY COURTDISTRICT OF NEW JERSEY
In re:
CHRISTOPHER & BANKS CORPORATION,
et al.,
Debtors.1
Chapter 11
Case No. 21-10269 (ABA)
Jointly Administered
HEARING DATE AND TIME:May 4, 2021, at 10:00 a.m. (EST)
NOTICE OF DEBTORS’ MOTIONTO AUTHORIZE CHANGE OF CASE CAPTION
PLEASE TAKE NOTICE that on May 4, 2021 at 10:00 a.m. (EST), or as soon
thereafter as counsel may be heard, Christopher & Banks Corporation and its subsidiaries, as
debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the
“Debtors”), by and through their undersigned counsel, shall move (the “Motion”) before the
Honorable Andrew B. Altenburg, Jr., United States Bankruptcy Judge, in Courtroom 4B of the
United States Bankruptcy Court for the District of New Jersey, Mitchell H. Cohen Courthouse,
1 The Debtors in these chapter 11 cases and the last four digits of each Debtor’s federal tax identification
number, as applicable, are as follows: Christopher & Banks Corporation (5422), Christopher & Banks, Inc. (1237),
and Christopher & Banks Company (2506). The Debtors’ corporate headquarters is located at 2400 Xenium Lane
North, Plymouth, Minnesota 55441.
Case 21-10269-ABA Doc 369 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc MainDocument Page 1 of 3
261893/0001-40341478v1
400 Cooper Street, Fourth Floor, Camden, New Jersey 08101, for the entry of an order,
substantially in the form submitted with the Motion, (i) authorizing a change of the case caption
and (ii) granting related relief, all as more fully set forth in the Motion.
PLEASE TAKE FURTHER NOTICE that the Motion sets forth the relevant factual
bases upon which the relief requested should be granted. A proposed Order granting the relief
requested in the Motion is also submitted herewith.
PLEASE TAKE FURTHER NOTICE that objections, if any, to the relief requested in
the Motion shall: (i) be in writing, (ii) state with particularity the basis of the objection, and
(iii) be filed with the Clerk of the United States Bankruptcy Court electronically by attorneys
who regularly practice before the Bankruptcy Court in accordance with the General Order
Regarding Electronic Means for Filing, Signing, and Verification of Documents dated March 27,
2002 (the “General Order”) and the Commentary Supplementing Administrative Procedures
dated as of March 2004 (the “Supplemental Commentary”) (the General Order, the
Supplemental Commentary and the User’s Manual for the Electronic Case Filing System can be
found at www.njb.uscourts.gov, the official website for the Bankruptcy Court) and, by all other
parties-in-interest, on CD-ROM in Portable Document Format (PDF), and shall be served in
accordance with the General Order and the Supplemental Commentary, so as to be received no
later than seven (7) days before the hearing date set forth above.
PLEASE TAKE FURTHER NOTICE that unless objections are timely filed, the
Motion shall be decided on the papers in accordance with D.N.J. LBR 9013-3(d), and the relief
requested may be granted without further notice or hearing.
Case 21-10269-ABA Doc 369 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc MainDocument Page 2 of 3
361893/0001-40341478v1
PLEASE TAKE FURTHER NOTICE that pursuant to D.N.J. LBR 9013-3(a), in the
event the Motion is contested, there is a duty to confer to determine whether a consent order may
be entered disposing of the Motion or to stipulate to the resolution of as many issues as possible.
PLEASE TAKE FURTHER NOTICE that in accordance with D.N.J. LBR 9013-3(e),
unless the Court authorizes otherwise prior to the hearing date hereof, no testimony shall be
taken at the hearing except by certification or affidavit.
DATED: April 9, 2021 COLE SCHOTZ P.C.Attorneys for Debtorsand Debtors in Possession
/s/ Michael D. SirotaMichael D. Sirota ([email protected])
Felice R. Yudkin ([email protected])
Jacob S. Frumkin ([email protected])
Matteo Percontino ([email protected])
Rebecca W. Hollander ([email protected])
Court Plaza North
25 Main Street
P.O. Box 800
Hackensack, New Jersey 07602-0800
Telephone: (201) 489-3000
Facsimile: (201) 489-1536
Case 21-10269-ABA Doc 369 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc MainDocument Page 3 of 3
61893/0001-40341478v1
COLE SCHOTZ P.C.Court Plaza North
25 Main Street
P.O. Box 800
Hackensack, New Jersey 07602-0800
(201) 489-3000
(201) 489-1536 Facsimile
Michael D. Sirota ([email protected])
Felice R. Yudkin ([email protected])
Jacob S. Frumkin ([email protected])
Matteo Percontino ([email protected])
Rebecca W. Hollander ([email protected])
Attorneys for Debtorsand Debtors in Possession
UNITED STATES BANKRUPTCY COURTDISTRICT OF NEW JERSEY
In re:
CHRISTOPHER & BANKS CORPORATION,
et al.,
Debtors.1
Chapter 11
Case No. 21-10269 (ABA)
Jointly Administered
DEBTORS’ MOTION TO AUTHORIZE CHANGE OF CASE CAPTION
Christopher & Banks Corporation and its above-captioned affiliated debtors and debtors
in possession (collectively, the “Debtors”) hereby submit this motion (the “Motion”) for entry
of an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”),
pursuant to section 105(a) of title 11 of the United States Code, 11 U.S.C. §§ 101 et seq. (the
“Bankruptcy Code”); Rules 1005, 2002(m), and 2002(n) of the Federal Rules of Bankruptcy
Procedure (the “Bankruptcy Rules”); and Rule 9004-1(a) of the Local Rules of Bankruptcy
Practice and Procedure of the United States Bankruptcy Court for the District of New Jersey (the
1 The Debtors in these chapter 11 cases and the last four digits of each Debtor’s federal tax identification
number, as applicable, are as follows: Christopher & Banks Corporation (5422), Christopher & Banks, Inc. (1237),
and Christopher & Banks Company (2506). The Debtors’ corporate headquarters is located at 2400 Xenium Lane
North, Plymouth, Minnesota 55441.
Case 21-10269-ABA Doc 369-1 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Debtors Motion to Authorize Change of Case Caption Page 1 of 6
61893/0001-40341478v1
“Local Rules”), authorizing the Debtors to amend the case captions used in these chapter 11
cases (collectively, the “Chapter 11 Cases”). In support of this Motion, the Debtors respectfully
represent as follows.
I. JURISDICTION AND VENUE
1. This Court has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157
and 1334 the Standing Order of Reference to the Bankruptcy Court Under Title 11 of the United
States District Court for the District of New Jersey, entered on July 23, 1984, and amended on
September 18, 2012 (Simandle, C.J.). This is a “core” proceeding within the meaning of 28
U.S.C. § 157(b)(2).
2. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409.
3. The statutory and legal bases for the relief requested herein are sections 105(a) of
the Bankruptcy Code, Bankruptcy Rules 1005, 2002, and 9004, and Local Rule 9004-1.
II. BACKGROUND
A. General Background
4. On January 13, 2021 (the “Petition Date”), each of the Debtors commenced with
this Court a voluntary case under chapter 11 of the Bankruptcy Code. The Debtors continue to
operate their businesses and manage their properties as debtors in possession pursuant to sections
1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in these
chapter 11 cases.
5. On January 26, 2021, the Office of the United States Trustee for the District of
New Jersey appointed an Official Committee of Unsecured Creditors (the “Committee”)
[Docket No. 118].
6. The Debtors’ cases are being jointly administered under lead Case No. 21-10269
pursuant to Bankruptcy Rule 1015 [Docket No. 45].
Case 21-10269-ABA Doc 369-1 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Debtors Motion to Authorize Change of Case Caption Page 2 of 6
61893/0001-40341478v1
7. Information regarding the Debtors’ business, capital structure, and the
circumstances leading to the commencement of these chapter 11 cases is set forth in the
Declaration of Keri L. Jones in Support of Debtors’ Chapter 11 Petitions and First Day Motions
(the “First Day Declaration”) [Docket No. 18].
8. The Debtors commenced these chapter 11 cases to facilitate a timely and efficient
process to maximize the value of their estates for the benefit of all stakeholders. The Debtors
immediately began to liquidate the inventory in their 449 retail stores (the “Store Closing
Sales”) and continued their pre-petition efforts to market and sell their remaining assets with the
assistance of their investment banker and other advisors.
9. On February 23, 2021, the Court entered an order approving the sale (the “Sale”)
of substantially all of the Debtors’ business assets to ALCC, LLC and/or one or more authorized
designees thereof (collectively, the “Purchaser”) [Docket No. 266] (the “Sale Order”). On
March 2, 2021, the Debtors closed on the Sale, with the Sale effective as of March 1, 2021.
10. Given the closing of the sale of their assets, the Debtors are currently in the
process of winding down their business operations and, on April 7, 2021, the Debtors filed a
motion to convert their chapter 11 cases to cases under chapter 7 [Docket No. 363].
B. Post-Closing Change of the Debtors’ Names
11. Paragraph 61 of the Sale Order requires the Debtors use commercially reasonable
efforts to change their corporate and company names as soon as reasonably practicable following
the Sale, providing as follows:
Change of Name. After the Closing, Sellers (and any of theirAffiliates) shall use reasonably commercial efforts to, as soon as
reasonably practicable (and in any event no later than 45 days after
the Closing Date), cease using any name, slogan, logo or
trademark which is similar or deceptively similar to any of the
names, trademarks or service marks included in the Intellectual
Property included in the Acquired Assets. In furtherance of the
Case 21-10269-ABA Doc 369-1 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Debtors Motion to Authorize Change of Case Caption Page 3 of 6
61893/0001-40341478v1
forgoing, Sellers shall use reasonably commercial efforts to, as
soon as reasonably practicable (and in any event no later than 45
days after the Closing Date), cease using the name “Christopher &
Banks” or any derivative thereof, either as a formal legal name,
assumed name, fictitious name, tradename, “doing business as” or
any other use, and following the closing Sellers shall take such
steps as are reasonable and appropriate to change the name and
caption of the Chapter 11 cases, upon application to the Court, in
connection with winding-up their estates or businesses to
discontinue use of such name or derivations thereof; provided,
however, the Sellers shall be permitted to use the “Christopher &
Banks” name as required to comply with any reporting or other
requirements with the Securities and Exchange Commission.
Without limiting the foregoing, effective as of the Closing, Sellers
hereby appoint Buyer as their attorney-in-fact for the limited
purpose of executing any documentation necessary to modify,
cancel, or terminate any “fictitious,” “doing business as,” trade
name, qualification to do business or foreign qualification filings
or registrations in any jurisdiction following the Closing. The
dissolution, liquidation, or winding-up of Sellers shall not
terminate such appointment or the authority and agency of the
Buyer provided pursuant to this Paragraph. The power-of-attorney
granted in this Paragraph is coupled with an interest and is
12. Pursuant to this authority granted in the Sale Order, the Debtors have filed, or will
soon file, the necessary paperwork with the secretaries of state (and any other relevant agencies)
in the Debtors’ respective states of incorporation to accomplish the required name changes from
a corporate perspective. The changes to each of the Debtors’ respective corporate names are as
follows:
Old Company Name New Company Name
Christopher & Banks Corporation CB Wind-Down Corporation
Christopher & Banks, Inc. CB Wind-Down, Inc.
Christopher & Banks Company CB Wind-Down Company, Inc.
III. RELIEF REQUESTED
13. By this Motion, the Debtors seek entry of an order pursuant to section 105(a) of
the Bankruptcy Code; Bankruptcy Rules 1005, 2002(m), and 2002(n); and Local Rule 9004-1(a)
Case 21-10269-ABA Doc 369-1 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Debtors Motion to Authorize Change of Case Caption Page 4 of 6
61893/0001-40341478v1
authorizing the Debtors to change their case captions to reflect the aforementioned changes to
their corporate names.
14. The Debtors request that, as set forth in the Proposed Order, (i) the case caption
used in each of these Chapter 11 Cases be amended to reflect the change of the Debtors’
corporate names, and (ii) the Court authorize and direct the Clerk of the United States
Bankruptcy Court for the District of New Jersey (the “Clerk of the Court”) and other parties in
interest to take any actions that are necessary to update the ECF filing system and their
respective records to reflect the proposed name changes, including the insertion of a docket entry
in each of the relevant Chapter 11 Cases announcing the change of the Debtors’ corporate names.
IV. BASIS FOR RELIEF REQUESTED
15. The Debtors respectfully submit that the relief requested herein is necessary and
appropriate as the Debtors have sold their intellectual property, including trademarks, to the
Purchaser and are required to change their corporate names pursuant to the Sale Order. Further,
the Debtors submit that the relief requested herein is routine in chapter 11 cases in situations
similar to those present here. See, e.g., In re Aceto Corporation, Case No. 19-13448 (VFP), Doc.
No. 607 (order approving motion to change debtors’ names and case captions); In re Quality
Conservation Services, Inc., Case No. 17-19603 (VFP), Doc. No. 136 (order approving motion to
change case caption in light of Debtor’s name change); In re Gaspari Nutrition, Inc., Case No.
14-30963 (CMG), Doc. No. 241 (order approving motion to change debtors’ names and case
captions); in re RCLC, Inc., f/k/a Ronson Corporation, Case No. 10-35313 (MBK), Doc. No. 194
(order approving motion to change case caption). Indeed, in some instances, debtors simply file
notices informing the court of their name change and the new caption applicable to their cases in
light of same. See, e.g., In re Congoleum Corporation, Case No. 20-18488 (MBK) (notice of
Case 21-10269-ABA Doc 369-1 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Debtors Motion to Authorize Change of Case Caption Page 5 of 6
61893/0001-40341478v1
name change and case caption); In re Adamar of New Jersey, Inc. and Manchester Mall, Inc.,
Case No. 09-20711 (JHW), Doc. No. 954 (notice of name change and case caption).
V. NOTICE
16. The Debtors have provided notice of this Motion to: (i) the Office of the United
States Trustee; (ii) counsel for the Committee; (iii) counsel for the Debtors’ prepetition secured
lender; (iv) the Internal Revenue Service; (v) the United States Attorney’s Office for the District
of New Jersey; (vi) the Securities and Exchange Commission; and (vii) any party requesting
notice pursuant to Bankruptcy Rule 2002. The Debtors submit that, in light of the nature of the
relief requested, no other or further notice need be given.
WHEREFORE, the Debtors respectfully request that the Court grant the relief requested
herein, and such other and further relief as it deems just and proper.
DATED: April 9, 2021 Respectfully submitted,
COLE SCHOTZ P.C.Attorneys for Debtorsand Debtors in Possession
/s/ Michael D. SirotaMichael D. Sirota ([email protected])
Felice R. Yudkin ([email protected])
Jacob S. Frumkin ([email protected])
Matteo Percontino ([email protected])
Rebecca W. Hollander ([email protected])
Court Plaza North
25 Main Street
P.O. Box 800
Hackensack, New Jersey 07602-0800
Telephone: (201) 489-3000
Facsimile: (201) 489-1536
Case 21-10269-ABA Doc 369-1 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Debtors Motion to Authorize Change of Case Caption Page 6 of 6
61893/0001-40341478v1
EXHIBIT A
Proposed Order
Case 21-10269-ABA Doc 369-2 Filed 04/09/21 Entered 04/09/21 09:37:15 DescExhibit A - Proposed Order Page 1 of 5
61893/0001-40341478v1
UNITED STATES BANKRUPTCY COURT
DISTRICT OF NEW JERSEY
Caption in Compliance with D.N.J. LBR 9004-1(b)
COLE SCHOTZ P.C.
Court Plaza North
25 Main Street
P.O. Box 800
Hackensack, New Jersey 07602-0800
Michael D. Sirota ([email protected])
Felice R. Yudkin ([email protected])
Jacob S. Frumkin ([email protected])
Matteo Percontino ([email protected])
Rebecca W. Hollander ([email protected])
(201) 489-3000
(201) 489-1536 Facsimile
Attorneys for Debtors
and Debtors in PossessionChapter 11
Case No. 21-10269 (ABA)
Jointly Administered
Hearing Date and Time:May 4, 2021 at 10:00 a.m. (EST)
In re:
CHRISTOPHER & BANKS CORPORATION,
et al.,
Debtors.1
ORDER GRANTING DEBTORS’ MOTIONTO AUTHORIZE CHANGE OF CASE CAPTION
The relief set forth on the following pages, numbered two (2) through five (5), is hereby
ORDERED.
1 The Debtors in these chapter 11 cases and the last four digits of each Debtor’s federal tax identification
number, as applicable, are as follows: Christopher & Banks Corporation (5422), Christopher & Banks, Inc. (1237),
and Christopher & Banks Company (2506). The Debtors’ corporate headquarters is located at 2400 Xenium Lane
North, Plymouth, Minnesota 55441.
Case 21-10269-ABA Doc 369-2 Filed 04/09/21 Entered 04/09/21 09:37:15 DescExhibit A - Proposed Order Page 2 of 5
Page (3)
Debtors: CHRISTOPHER & BANKS CORPORATION, et al.Case No. 21-10269 (ABA)
Caption of Order: ORDER GRANTING DEBTORS’ MOTION TO AUTHORIZE
CHANGE OF CASE CAPTION
61893/0001-40341478v1
Upon the motion (the “Motion”)2 of the above-captioned debtors and debtors in
possession (collectively, the “Debtors”) for entry of an order pursuant to section 105(a) of the
Bankruptcy Code; Bankruptcy Rules 1005, 2002(m), and 2002(n); and Local Rule 9004-1(a),
authorizing the Debtors to change the case captions used in the Chapter 11 Cases; and due and
proper notice of the Motion having been given; and it appearing that no other or further notice of
the Motion is required; and the Court having jurisdiction to decide the Motion and grant the
relief requested therein in accordance with 28 U.S.C. §§ 157(a)-(b) and 1334(b) and the Standing
Order of Reference to the Bankruptcy Court Under Title 11 of the United States District Court
for the District of New Jersey, entered on July 23, 1984, and amended on September 18, 2012
(Simandle, C.J.); and it appearing that this is a core proceeding pursuant to 28 U.S.C. §
157(b)(2); and it appearing that venue of this proceeding and the Motion is proper pursuant to 28
U.S.C. §§ 1408 and 1409; and after due deliberation and sufficient cause appearing therefor,
IT IS HEREBY ORDERED THAT:
1. The Clerk of the Court is authorized and directed to make a docket entry in case
number 21-10269 (ABA) as soon as possible that states substantially as follows: “An order has
been entered in this case directing that the caption of this case be changed, in accordance with
the corporate name change of Christopher & Banks Corporation to CB Wind-Down
2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the
Motion.
Case 21-10269-ABA Doc 369-2 Filed 04/09/21 Entered 04/09/21 09:37:15 DescExhibit A - Proposed Order Page 3 of 5
Page (4)
Debtors: CHRISTOPHER & BANKS CORPORATION, et al.Case No. 21-10269 (ABA)
Caption of Order: ORDER GRANTING DEBTORS’ MOTION TO AUTHORIZE
CHANGE OF CASE CAPTION
61893/0001-40341478v1
Corporation.” In addition, the Clerk of the Court is authorized and directed to modify the docket
of case number 21-10269 (ABA) with the Debtor’s new name as soon as possible.
2. Effective as of the date hereof, the new caption of the jointly administered
Chapter 11 Cases shall read as follows:
UNITED STATES BANKRUPTCY COURTDISTRICT OF NEW JERSEY
In re:
CB WIND-DOWN CORPORATION, et al.,
Debtors.1
Chapter 11
Case No. 21-10269 (ABA)
Jointly Administered
FN1: The Debtors in these chapter 11 cases and the last four digits of each Debtor’s
federal tax identification number, as applicable, are as follows: CB Wind-Down
Corporation (f/k/a Christopher & Banks Corporation) (5422), CB Wind-Down, Inc. (f/k/aChristopher & Banks, Inc.) (1237), and CB Wind-Down Company, Inc. (f/k/aChristopher & Banks Company) (2506).
3. The Clerk of the Court is authorized and directed to make a docket entry in case
number 21-10268 (ABA) as soon as possible that states substantially as follows: “An order has
been entered in this case directing that the caption of this case be changed, in accordance with
the corporate name change of “Christopher & Banks Inc. to CB Wind-Down, Inc.” In addition,
the Clerk of the Court is authorized and directed to modify the docket of case number 21-10268
(ABA) with the Debtor’s new name as soon as possible.
Case 21-10269-ABA Doc 369-2 Filed 04/09/21 Entered 04/09/21 09:37:15 DescExhibit A - Proposed Order Page 4 of 5
Page (5)
Debtors: CHRISTOPHER & BANKS CORPORATION, et al.Case No. 21-10269 (ABA)
Caption of Order: ORDER GRANTING DEBTORS’ MOTION TO AUTHORIZE
CHANGE OF CASE CAPTION
61893/0001-40341478v1
4. The Clerk of the Court is authorized and directed to make a docket entry in case
number 21-10270 (ABA) as soon as possible that states substantially as follows: “An order has
been entered in this case directing that the caption of this case be changed, in accordance with
the corporate name change of Christopher & Banks Company to CB Wind-Down Company,
Inc.” In addition, the Clerk of the Court is authorized and directed to modify the docket of case
number 21-10270 (ABA) with the Debtor’s new name as soon as possible.
5. The Debtors are authorized and empowered to take all actions necessary to
implement the relief granted in this Order.
6. The Court shall retain jurisdiction with respect to all matters arising from or
related to the implementation of this Order.
Case 21-10269-ABA Doc 369-2 Filed 04/09/21 Entered 04/09/21 09:37:15 DescExhibit A - Proposed Order Page 5 of 5
61893/0001-40341478v1
COLE SCHOTZ P.C.Court Plaza North
25 Main Street
P.O. Box 800
Hackensack, New Jersey 07602-0800
(201) 489-3000
(201) 489-1536 Facsimile
Michael D. Sirota ([email protected])
Felice R. Yudkin ([email protected])
Jacob S. Frumkin ([email protected])
Matteo Percontino ([email protected])
Rebecca W. Hollander ([email protected])
Attorneys for Debtorsand Debtors in Possession
UNITED STATES BANKRUPTCY COURTDISTRICT OF NEW JERSEY
In re:
CHRISTOPHER & BANKS CORPORATION,
et al.,
Debtors.1
Chapter 11
Case No. 21-10269 (ABA)
Jointly Administered
DECLARATION OF KARA JOHNSON IN SUPPORT OFDEBTORS’ MOTION TO AUTHORIZE CHANGE OF CASE CAPTION
I, Kara Johnson, make this declaration under 28 U.S.C. § 1746:
1. I am Chief Financial Officer of Christopher & Banks Corporation and its
subsidiaries, the debtors and debtors in possession in the above-referenced chapter 11 cases (the
“Debtors”). I have served in that capacity since January of 2021. Prior to that, I served as the
Debtors' Vice President of Financial Planning & Analysis beginning in July of 2020 and their
Director of Financial Planning & Analysis beginning in September of 2016. Before joining the
1 The Debtors in these chapter 11 cases and the last four digits of each Debtor’s federal tax identification
number, as applicable, are as follows: Christopher & Banks Corporation (5422), Christopher & Banks, Inc. (1237),
and Christopher & Banks Company (2506). The Debtors’ corporate headquarters is located at 2400 Xenium Lane
North, Plymouth, Minnesota 55441.
Case 21-10269-ABA Doc 369-3 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Declaration of Kara Johnson in Support of Debtors Motion to Authorize Ch Page 1 of 4
261893/0001-40341478v1
Debtors, I held roles as Business Intelligence Manager for LEGO Group (from 2015 to 2016),
Finance Manager and Financial Analyst for PetSmart, Inc. (from 2013 to 2015 and 2010 to 2013,
respectively), and Assistant Project Manager and Project Engineer for The Weitz Company
(from 2006 to 2009 and 2003 to 2006, respectively).
2. This Declaration is submitted in support of the Debtors’ Motion to Authorize
Change of Case Caption (the “Motion”).2 Except as otherwise indicated herein, the facts set
forth in this declaration are based upon my personal knowledge, my review of relevant
documents, information provided to me by the Debtors’ employees, or my opinion based upon
my experience, knowledge, and information concerning the Debtors’ operations and the retail
industry. I am authorized to submit this declaration on the Debtors’ behalf. If called upon to
testify, I would testify competently to the facts set forth in this declaration.
A. The Chapter 11 Cases
3. On January 13, 2021 (the “Petition Date”), each of the Debtors commenced with
this Court a voluntary case under chapter 11 of the Bankruptcy Code. The Debtors continue to
operate their businesses and manage their properties as debtors in possession pursuant to
sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed
in these chapter 11 cases.
4. On January 26, 2021, the Office of the United States Trustee for the District of
New Jersey appointed an Official Committee of Unsecured Creditors (the “Committee”)
[Docket No. 118].
5. The Debtors’ cases are being jointly administered under lead Case No. 21-10269
pursuant to Bankruptcy Rule 1015 [Docket No. 45].
2 Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Motion.
Case 21-10269-ABA Doc 369-3 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Declaration of Kara Johnson in Support of Debtors Motion to Authorize Ch Page 2 of 4
361893/0001-40341478v1
6. Information regarding the Debtors’ business, capital structure, and the
circumstances leading to the commencement of these chapter 11 cases is set forth in the
Declaration of Keri L. Jones in Support of Debtors’ Chapter 11 Petitions and First Day Motions
(the “First Day Declaration”) [Docket No. 18].
7. The Debtors commenced these chapter 11 cases to facilitate a timely and efficient
process to maximize the value of their estates for the benefit of all stakeholders. The Debtors
immediately began to liquidate the inventory in their 449 retail stores (the “Store Closing
Sales”) and continued their pre-petition efforts to market and sell their remaining assets with the
assistance of their investment banker and other advisors.
8. On February 23, 2021, the Court entered an order approving the sale (the “Sale”)
of substantially all of the Debtors’ business assets to ALCC, LLC (the “Purchaser”) [Docket
No. 266] (the “Sale Order”). On March 2, 2021, the Debtors closed on the Sale, with the Sale
effective as of March 1, 2021.
9. Given the closing of the sale of their assets, the Debtors are currently in the
process of winding down their business operations and, on April 7, 2021, the Debtors filed a
motion to convert their chapter 11 cases to cases under chapter 7 [Docket No. 363]. In
connection with their efforts to wind down their affairs, in accordance with the Sale Order, the
Debtors are required to cease using the name “Christopher & Banks.” Therefore, the Debtors
have changed their names or are in the process of changing their names as follows:
Old Company Name New Company Name
Christopher & Banks Corporation CB Wind-Down Corporation
Christopher & Banks, Inc. CB Wind-Down, Inc.
Christopher & Banks Company CB Wind-Down Company, Inc.
Case 21-10269-ABA Doc 369-3 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Declaration of Kara Johnson in Support of Debtors Motion to Authorize Ch Page 3 of 4
461893/0001-40341478v1
10. As set forth in the Motion, the Debtors seek to change the caption of their Chapter
11 Cases to be consistent with their new corporate names.
11. The relief requested in the Motion is consistent with the terms of the Sale Order
and the agreement reached between the Debtors and the Purchaser. Accordingly, I submit that
cause exists to grant the relief requested in the Motion.
I declare under penalty of perjury that, to the best of my knowledge and after reasonable
inquiry, the foregoing is true and correct.
Executed this 9th day of April, 2021
/s/ Kara JohnsonKARA JOHNSON
CHIEF FINANCIAL OFFICER
Case 21-10269-ABA Doc 369-3 Filed 04/09/21 Entered 04/09/21 09:37:15 Desc Declaration of Kara Johnson in Support of Debtors Motion to Authorize Ch Page 4 of 4