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73936836.1
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: LUCKY’S MARKET PARENT COMPANY, LLC, et al.,1
Debtors.
Chapter 11 Case No. 20-10166 (JTD) (Jointly Administered) Re: Docket No. 805
NOTICE OF FILING OF EXHIBITS TO OBJECTION OF THE DEBTORS TO ATA
FORUM LOUISVILLE, KY, LLC'S APPLICATION FOR ALLOWANCE OF ADMINISTRATIVE CLAIMS UNDER 11 U.S.C. §§ 105, 503(B) AND 365(D)(3)
PLEASE TAKE NOTICE that, on June 17, 2020, the above-captioned debtors and
debtors in possession (collectively, the “Debtors”) filed the Objection of the Debtors to ATA
Forum Louisville, KY, LLC's Application for Allowance of Administrative Claims Under 11 U.S.C.
§§ 105, 503(b) and 365(d)(3) [Docket No. 805] (the “Objection”) with the United States
Bankruptcy Court for the District of Delaware (the “Bankruptcy Court”).
PLEASE TAKE FURTHER NOTICE that attached hereto are exhibits to the Objection.
1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are Lucky’s Market Parent Company, LLC (2055), Lucky’s Farmers Market Holding Company, LLC (5480), Lucky’s Market Operating Company, LLC (7064), LFM Stores LLC (3114), Lucky’s Farmers Market, LP (0828), Lucky’s Farmers Market Resource Center, LLC (7711), Lucky’s Market Holding Company 2, LLC (0607), Lucky’s Market GP 2, LLC (9335), Lucky’s Market 2, LP (8384), Lucky’s Market of Longmont, LLC (9789), Lucky’s Farmers Market of Billings, LLC (8088), Lucky’s Farmers Markets of Columbus, LLC (3379), Lucky’s Farmers Market of Rock Hill, LLC (3386), LFM Jackson, LLC (8300), Lucky’s Farmers Market of Ann Arbor, LLC (4067), Lucky’s Market of Gainesville, LLC (7877), Lucky’s Market of Bloomington, LLC (3944), Lucky’s Market of Plantation, LLC (4356), Lucky’s Market of Savannah, GA, LLC (1097), Lucky’s Market of Traverse, City, LLC (2033), Lucky’s Market of Naples, FL, LLC (8700), Sinoc, Inc. (0723), Lucky’s Farmers Market of Ellisville, LLC (2875), and Lucky’s Farmers Market of Lexington, KY, LLC (3446).
Case 20-10166-JTD Doc 807 Filed 06/18/20 Page 1 of 2
2 73936836.1
Dated: June 18, 2020 Wilmington, Delaware
Respectfully submitted,
POLSINELLI PC /s/ Christopher A. Ward Christopher A. Ward (Del. Bar No. 3877) 222 Delaware Avenue, Suite 1101 Wilmington, Delaware 19801 Telephone: (302) 252-0920 Facsimile: (302) 252-0921 [email protected]
-and-
Liz Boydston (Admitted Pro Hac Vice) 2950 N. Harwood, Suite 2100 Dallas, Texas 75201 Telephone: (214) 661-5557 [email protected] Counsel to the Debtors and Debtors in Possession
Case 20-10166-JTD Doc 807 Filed 06/18/20 Page 2 of 2
EXHIBIT A
Case 20-10166-JTD Doc 807-1 Filed 06/18/20 Page 1 of 3
73780099.7
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re:
LUCKY’S MARKET PARENT COMPANY, LLC, et al.,1
Debtors.
Chapter 11
Case No. 20-10166 (JTD)
(Jointly Administered)
Re: Docket No.
ORDER DENYING MOTION FOR ALLOWANCE OF ADMINISTRATIVE CLAIM
Upon consideration of the motion of ATA Landlord Louisville KY, LLC (“Landlord”)
for allowance and payment of an administrative claim (the “Motion”), and the Debtors’
objection thereto (the “Objection”); and this Court having jurisdiction over the Motion and
Objection 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 February 29, 2012; and
this Court having found that this matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2),
and that the Debtors consent to entry of a final order under Article III of the United States
Constitution; and this Court having found that venue of this proceeding, the Motion, and the
Objection in this District are proper pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court
having determined that granting the relief requested in the Objection as set forth in this Order is
in the best interests of the above-captioned debtors and debtors in possession (each, a “Debtor”
and collectively, the “Debtors”), their estates, and creditors; and notice of the Objection being
1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are Lucky’s Market Parent Company, LLC (2055), Lucky’s Farmers Market Holding Company, LLC (5480), Lucky’s Market Operating Company, LLC (7064), LFM Stores LLC (3114), Lucky’s Farmers Market, LP (0828), Lucky’s Farmers Market Resource Center, LLC (7711), Lucky’s Market Holding Company 2, LLC (0607), Lucky’s Market GP 2, LLC (9335), Lucky’s Market 2, LP (8384), Lucky’s Market of Longmont, LLC (9789), Lucky’s Farmers Market of Billings, LLC (8088), Lucky’s Farmers Markets of Columbus, LLC (3379), Lucky’s Farmers Market of Rock Hill, LLC (3386), LFM Jackson, LLC (8300), Lucky’s Farmers Market of Ann Arbor, LLC (4067), Lucky’s Market of Gainesville, LLC (7877), Lucky’s Market of Bloomington, LLC (3944), Lucky’s Market of Plantation, LLC (4356), Lucky’s Market of Savannah, GA, LLC (1097), Lucky’s Market of Traverse, City, LLC (2033), Lucky’s Market of Naples, FL, LLC (8700), Sinoc, Inc. (0723), Lucky’s Farmers Market of Ellisville, LLC (2875), and Lucky’s Market of Lexington, KY, LLC (3446).
Case 20-10166-JTD Doc 807-1 Filed 06/18/20 Page 2 of 3
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sufficient under the circumstances; and after due deliberation and sufficient cause appearing
therefor,
IT IS HEREBY AGREED, ORDERED, ADJUDGED AND DECREED AS FOLLOWS:
1. The Objection is sustained and the relief requested therein is granted.
2. The Motion is denied in its entirety.
3. Landlord shall not be entitled to any administrative claim pursuant to Bankruptcy
Code section 503(b).
4. Nothing contained herein shall constitute, nor shall it be deemed to constitute, the
allowance of any claim asserted against the Debtors’ estates.
5. This Court shall retain jurisdiction to hear any disputes arising out of the
implementation of this Order.
Dated: _______________, 2020 Wilmington, Delaware
_________________________________________ THE HONORABLE JOHN T. DORSEY
UNITED STATES BANKRUPTCY JUDGE
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EXHIBIT B
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EXHIBIT C
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73886884.1
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: LUCKY’S MARKET PARENT COMPANY, LLC, et al.,1
Debtors.
Chapter 11 Case No. 20-10166 (JTD) (Jointly Administered) Re: Docket Nos.
DECLARATION OF CHAD RENIER IN SUPPORT OF THE
OBJECTION OF THE DEBTORS TO ATA FORUM LOUISVILLE KY, LLC’S APPLICATION FOR ALLOWANCE OF ADMINISTRATIVE CLAIMS
UNDER 11 U.S.C. §§ 105, 503(b), AND 365(d)(3)
Pursuant to 28 U.S.C. § 1764, Chad Renier, declares as follows under the penalty of
perjury:
1. I am the Chief Executive Officer of Mechanical Removal & Relocation, LLC
(“MR&R”), a company specializing in the removal, relocation, and resale of personal property,
including furniture, fixtures, and equipment (“FF&E”). I have been in the business of the removal,
relocation, and resale of FF&E for 18 years.
2. On approximately 12 separate occasions, I purchased FF&E from Great American,
including purchasing the FF&E from the Debtors’ Jackson, Wyoming store and the Debtors’
Louisville, Kentucky store.
1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are Lucky’s Market Parent Company, LLC (2055), Lucky’s Farmers Market Holding Company, LLC (5480), Lucky’s Market Operating Company, LLC (7064), LFM Stores LLC (3114), Lucky’s Farmers Market, LP (0828), Lucky’s Farmers Market Resource Center, LLC (7711), Lucky’s Market Holding Company 2, LLC (0607), Lucky’s Market GP 2, LLC (9335), Lucky’s Market 2, LP (8384), Lucky’s Market of Longmont, LLC (9789), Lucky’s Farmers Market of Billings, LLC (8088), Lucky’s Farmers Markets of Columbus, LLC (3379), Lucky’s Farmers Market of Rock Hill, LLC (3386), LFM Jackson, LLC (8300), Lucky’s Farmers Market of Ann Arbor, LLC (4067), Lucky’s Market of Gainesville, LLC (7877), Lucky’s Market of Bloomington, LLC (3944), Lucky’s Market of Plantation, LLC (4356), Lucky’s Market of Savannah, GA, LLC (1097), Lucky’s Market of Traverse, City, LLC (2033), Lucky’s Market of Naples, FL, LLC (8700), Sinoc, Inc. (0723), Lucky’s Farmers Market of Ellisville, LLC (2875), and Lucky’s Farmers Market of Lexington, KY, LLC (3446).
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73886884.1
3. I submit this declaration (this “Declaration”) in support of the Objection of the
Debtors to ATA Forum Louisville KY, LLC’s Application for Allowance of Administrative Claims
under 11 U.S.C. §§ 105, 503(b), and 365(d)(3) (the “Motion”).2
4. On February 4, 2020, I agreed to purchase the Louisville FF&E from the Debtors
for the purchase price of $20,000, evidenced by that certain Invoice #80015, a true and correct
copy of which is attached to the Motion as Exhibit F (the “FF&E Invoice”). The FF&E Invoice
lists the categories of property I purchased.
5. On or about February 6, 2020, I sent a crew for initial review of the Louisville
FF&E to determine the type and number of machinery and tools needed to remove the Louisville
FF&E. A Great American representative, Clarissa Mclean, was present and supervised my crew.
6. Over the next few days, my crew proceeded to package all small appliances and
disassemble equipment that was located behind areas that were inaccessible to the public. Once
the Freon for the refrigeration was pumped out, my crew then proceeded to prepare the
refrigeration cases for removal. On each of these days, Ms. Mclean of Great American was present
and supervised my team.
7. On February 12, 2020, after assessing the progress of the removal preparation, I
ordered two scrap dumpsters and a garbage dumpster and scheduled a crane for removal of the
condenser on the rooftop. As of February 12, 2020, most of the Louisville FF&E was staged for
removal, but none of the Louisville FF&E had been removed.
8. On February 12, 2020, my crew and I arrived at the Louisville Store to commence
removal of the Louisville FF&E. After unloading my forklifts and heavy equipment, Ms. Mclean
informed me that she had received a phone call from Jeremy Hamilton, who introduced himself as
2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Motion.
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73886884.1
the property manager on behalf of the Landlord. Ms. Mclean also informed me that Mr. Hamilton
had ordered Ms. Mclean to stop any further removal immediately and that he was sending a
representative with the sheriff to stop all removal.
9. A representative of the Landlord came to the Louisville Store with a locksmith to
change the locks. While the Landlord’s representative spoke with Ms. Mclean in person, I spoke
on the phone with Mr. Hamilton.
10. For nearly an hour, the Landlord representative and Mr. Hamilton, by phone, both
asserted that Landlord owned the equipment and that my crew and I were trespassing. Mr.
Hamilton told me that he would send a Landlord representative the next day to oversee me and my
crew as we remove the Louisville FF&E.
11. In an effort to avoid an unnecessary confrontation, Ms. Mclean informed me that
my crew and I would not be able to remove any of the Louisville FF&E until further notice. My
crew and I did not remove any Louisville FF&E that day. Ms. Mclean closed the Louisville Store
for the day and my crew and I left the premises.
12. On February 13, 2020, my crew continued packaging the Louisville FF&E for
removal, but we did not remove any of the Louisville FF&E. From my phone conversation with
Mr. Hamilton the day before, I expected the Landlord representative to arrive at the Louisville, but
the Landlord representative never showed. I had to once again reschedule the arrival of my removal
team, trucks, and the crane.
13. On February 14, 2020, I again expected the Landlord’s representative to arrive.
However, once again, a Landlord representative never showed. Ms. Mclean called Mr. Hamilton,
who informed her that a Landlord representative would not be at the Louisville Store until
sometime on February 18, 2020.
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14. As a result, I again had to cancel and reschedule removal of the personalty and
Louisville FF&E, including rescheduling trucks and a crane. I also lost sales on certain of the
Louisville FF&E, including the walk-ins, hoods, the rooftop unit, and the checkout counters.
15. The Landlord refused to send a representative for nearly a week. This substantial
and unreasonable delay was at my expense as I had to reschedule the contractors and machinery
necessary to remove the Louisville FF&E multiple times and pay for lodging and meals for myself
and my crew for the extra days the Landlord refused to show up.
16. Around 6:30 p.m. eastern on February 14, 2020, I received confirmation from the
Debtors and their professionals that I could recommence removal of the personalty and Louisville
FF&E. While there was still a bit of daylight, my crew and I began hauling garbage and scrap
metal to the dumpsters in the parking lot.
17. On February 15, my crew removed kitchen equipment, such as ovens, meat slicers,
scales, a smoker, a coffee grinder, juicers, and other small wares from the Louisville Store and
loaded it into one of the 18-wheelers I rented for the relocation of the Louisville FF&E. My crew
also prepared the rooftop units for the captive air hoods and the condensing unit for removal,
including cutting the refrigeration copper going from the compressors to the cases. My crew split
and scrapped all of the junk cases. My crew hauled several loads to the scrap yard and filled two
scrap dumpsters of shelving and miscellaneous metal.
18. On Monday, February 17, 2020, I had a crane remove the equipment from the roof.
My crew continued to haul scrap to the scrap yard and clean up the Louisville Store.
19. On Tuesday, February 18, 2020, I had planned to complete removal of the
Louisville FF&E but was interrupted by Mr. Hamilton. Mr. Hamilton again demanded that I stop
removal of the Louisville FF&E and threatened to call the police to arrest Ms. Mclean. As a result
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of Mr. Hamilton’s threats and demands, I was forced to leave the Louisville Store. Thus, I was
unable to finish cleanup of the Louisville Store.
20. Although I was unable to broom clean the premises due to the Landlord’s hasty
eviction of me and my crew, we did not leave the property damaged.
21. I had two 18-wheelers that were intended to hold the Louisville FF&E. Only one
of the 18-wheelers was close to filled, while the other was nearly empty.
22. In addition to the kitchen equipment detailed above, I was able to remove only the
metro racks, some of the glass door cases, some shelving, stainless tables, stainless sinks, printers,
the evaporation coils, the captive air hoods, and most of the electronics for the checkout system.
23. I was also forced to leave a significant amount of the Louisville FF&E I had
purchased behind, including, but not limited to: (i) the walk-in coolers; (ii) refrigerated cases and
shelving; (iii) pallets of clean radiators; (iv) two hot bars; (v) a pizza warming station; (vi) a
kegerator; (vii) the checkout counters; (viii) most of the POS system, including the control
modules, battery backup, and IT rack; (ix) all of the office equipment; and (x) the air curtains that
keep the air conditioning inside when the store’s doors are continuously opened.
Executed this 17th of day of June, 2020.
/s/ Chad Renier
CEO of Mechanical Removal & Relocation, LLC
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EXHIBIT D
Case 20-10166-JTD Doc 807-4 Filed 06/18/20 Page 1 of 6
73887438.1
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: LUCKY’S MARKET PARENT COMPANY, LLC, et al.,1
Debtors.
Chapter 11 Case No. 20-10166 (JTD) (Jointly Administered) Re: Docket Nos.
DECLARATION OF CLARISSA MCLEAN IN SUPPORT OF THE
OBJECTION OF THE DEBTORS TO ATA FORUM LOUISVILLE KY, LLC’S APPLICATION FOR ALLOWANCE OF ADMINISTRATIVE CLAIMS
UNDER 11 U.S.C. §§ 105, 503(b), AND 365(d)(3)
Pursuant to 28 U.S.C. § 1764, Clarissa Mclean, declares as follows under the penalty of
perjury:
1. I have been a Liquidation Consultant for 6 years. Great American Global Partners,
LLC (“Great American”) was hired by the Debtors to assist with the sale of furniture, fixtures,
and equipment (“FF&E”) for certain of the Debtors’ stores. Great American hired me as an
independent contractor to oversee the sale and removal of the Louisville FF&E. I have worked for
Great American at least 4 times over the past 5 years. In addition to Great American, I have worked
as a Liquidation Consultant for other liquidation companies, including the Tiger Capital Group
1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are Lucky’s Market Parent Company, LLC (2055), Lucky’s Farmers Market Holding Company, LLC (5480), Lucky’s Market Operating Company, LLC (7064), LFM Stores LLC (3114), Lucky’s Farmers Market, LP (0828), Lucky’s Farmers Market Resource Center, LLC (7711), Lucky’s Market Holding Company 2, LLC (0607), Lucky’s Market GP 2, LLC (9335), Lucky’s Market 2, LP (8384), Lucky’s Market of Longmont, LLC (9789), Lucky’s Farmers Market of Billings, LLC (8088), Lucky’s Farmers Markets of Columbus, LLC (3379), Lucky’s Farmers Market of Rock Hill, LLC (3386), LFM Jackson, LLC (8300), Lucky’s Farmers Market of Ann Arbor, LLC (4067), Lucky’s Market of Gainesville, LLC (7877), Lucky’s Market of Bloomington, LLC (3944), Lucky’s Market of Plantation, LLC (4356), Lucky’s Market of Savannah, GA, LLC (1097), Lucky’s Market of Traverse, City, LLC (2033), Lucky’s Market of Naples, FL, LLC (8700), Sinoc, Inc. (0723), Lucky’s Farmers Market of Ellisville, LLC (2875), and Lucky’s Farmers Market of Lexington, KY, LLC (3446).
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73887438.1
and Liquid Asset Partners, LLC. Over the past 6 years, I have overseen the sale and removal of
FF&E on more than 50 separate occasions.
2. I submit this declaration (this “Declaration”) in support of the Objection of the
Debtors to ATA Forum Louisville KY, LLC’s Application for Allowance of Administrative Claims
under 11 U.S.C. §§ 105, 503(b), and 365(d)(3) (the “Motion”).2
3. Great American marketed the Debtors’ FF&E online through social media as well
as by cold calling local companies and contacting dealers all over the country.
4. There was only one bulk bid for the Louisville FF&E as most dealers did not want
the Louisville FF&E because of its age and condition. Chad Renier of Mechanical Removal &
Relocation, LLC (the “Buyer”) submitted the sole bid.
5. Buyer agreed to buy the Louisville FF&E for the purchase price of $20,000,
evidenced by that certain Invoice #80015, a true and correct copy of which is attached to the
Motion as Exhibit F (the “FF&E Invoice”).
6. Great American also located buyers for certain of the Louisville FF&E not included
in the FF&E Invoice, which resulted in collective sales of about $5,000.
7. On or about February 6, 2020, the Buyer’s crew arrived at the Louisville Store for
their initial review of the Louisville FF&E. I was present and supervised the Buyer’s team.
8. Over the next few days, the Buyer’s crew proceeded to package all small appliances
and disassemble equipment that was located behind areas that were inaccessible to the public.
Once the Freon for the refrigeration was pumped out, Buyer’s crew then proceeded to prepare the
refrigeration cases for removal. On each of these days, I was present and supervised the Buyer’s
team.
2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Motion.
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9. On each of February 10, 11, and 12, I unlocked the store and was present and
supervised the Buyer’s team.
10. As of February 12, 2020, none of the Louisville FF&E had been removed.
11. On February 12, 2020, the Buyer arrived at the Louisville Store to commence
removal of the Louisville FF&E. After Buyer unloaded forklifts and heavy equipment, I received
a phone call from Jeremy Hamilton, who introduced himself as the property manager on behalf of
Landlord. Mr. Hamilton inquired as to the progress of the removal of the Louisville FF&E and
ordered me to stop any further removal immediately. Mr. Hamilton also informed me that he was
sending a representative with the sheriff to stop all removal.
12. A representative of the Landlord came to the Louisville Store with a locksmith to
change the locks. For nearly an hour, the Landlord representative and Mr. Hamilton, by phone,
asserted that Landlord owned the equipment and that the Buyer and Great American were
trespassing. In an effort to avoid an unnecessary confrontation, I, after discussing the matter with
my superior Dennis Jenkins, informed Buyer that he would not be able to remove any more of the
Louisville FF&E until further notice. Buyer did not remove any Louisville FF&E that day. I closed
and locked the Louisville Store for the day, and all parties left the premises.
13. I was informed that the Debtors had agreed to postpone removal to permit the
Landlord’s representative to be present during the removal of the Louisville FF&E the next day.
14. On February 13, 2020, Buyer and his crew continued packaging the Louisville
FF&E for removal, but they did not remove any of the Louisville FF&E. I expected the Landlord
representative to arrive at the Louisville Store, but the Landlord representative never showed.
15. On February Friday 14, 2020, I again expected the Landlord’s representative to
arrive. However, once again, a Landlord representative never showed. I called Mr. Hamilton to
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inquire as to when the Landlord representative would arrive. Despite having already sent a
representative two days earlier to halt the removal of the Louisville FF&E, Mr. Hamilton
responded that a Landlord representative would not be at the Louisville Store until sometime on
February 18, 2020.
16. I informed my supervisor Dennis Jenkins that the Landlord’s representative would
not arrive until sometime on February 18, 2020. He informed me that he was reaching out to
Debtors’ counsel.
17. Around 6:30 p.m. eastern on February 14, 2020, I received confirmation from
Dennis Jenkins that the Debtors and their professionals authorized the Buyer to commence removal
of the personalty and Louisville FF&E. I informed Buyer.
18. While there was still a bit of daylight, Buyer’s crew began hauling garbage and
scrap metal to the dumpsters in the parking lot.
19. On February 15, 2020, I once again unlocked the store for Buyer and his crew.
Buyer removed kitchen equipment and other small appliances. Buyer and his team prepared the
rooftop units and the condensing unit for removal, including cutting the refrigeration copper going
from the compressors to the cases. Buyer split and scrapped all of the junk cases. Buyer hauled
several loads to the scrap yard and filled two scrap dumpsters of shelving and miscellaneous metal.
20. On Monday, February 17, 2020, Buyer had a crane remove the equipment from the
roof. Buyer continued to haul scrap to the scrap yard and began to clean up the Louisville Store.
21. On Tuesday, February 18, 2020, while Buyer’s crew was continuing to break down
and started to load the Louisville FF&E, Mr. Hamilton arrived at the Louisville Store and
demanded the Buyer stop his removal of the Louisville FF&E. Mr. Hamilton threatened to call the
police to arrest me.
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22. As a result of Mr. Hamilton’s threats and demands, I was forced to leave the
Louisville Store. Buyer and his crew were forced out of the store as well. Buyer was unable to load
most of the FF&E, and he was unable to finish the cleanup of the Louisville Store.
Executed this 17th of day of June, 2020.
/s/ Clarissa McLean Liquidation Consultant
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EXHIBIT E
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EXHIBIT F
Case 20-10166-JTD Doc 807-6 Filed 06/18/20 Page 1 of 2
12LOU
LOUISVILLE KY
80015
INVOICE
BUYER CHAD RENIER SALES DATE 2/4/2020 PICK UP DATE TBD
COMPANY MECHANICAL REMOVAL & RELOCATION LLC
ADDRESS N3069 N 9TH RD PHONE # 920-737-8450 E-MAIL ADDRESS [email protected]
CITY COLEMAN
STATE WI FAX#
ZIP CODE 54112 TAX EXEMPT #
CASH CHECK CREDIT X WIRE DATE OF WIRE
TERMS
QTY ITEM PRICE TOTAL
1 20,000.00$
5,000.00$
TOTAL 20,000.00$
BUYERS PREMIUM -$
SUB TOTAL 20,000.00$
SALES TAX -$
RESALE CERTIFICATE SIGNATURE ______________________ DEPOSIT -$
DATE AUTHORIZED________________________ BALANCE 20,000.00$
HANDHELD COMPUTERS, TABLET COMPUTERS, LAPTOP COMPUTERS,
Customer copy ALL SALES FINAL
Great American Global Partners
26635 Agoura Rd, Suite 215
ALL REMOVAL MUST BE DONE IN A PROFESSIONAL WORKMAN LIKE MANNER, NO
DEMOLITION, FACILITY MUST BE LEFT BROOM CLEAN WITH ALL TRASH REMOVED.
ALL CONTRACTORS MUST PROVIDE PROOF OF LIABILITY INSURANCE BEFORE ANY
WORK BEGINS FOR ELECTRICAL, PLUMBING, MAJOR MECHANICAL, AND REFRIGERATION.
FIRE ALARMS, BURGLER ALARMS, DOORS, WALLS, CEILINGS, ROOFS, WINDOWS,
ELECTRICAL TRANSFORMERS, ELECTRICAL BOXES, BATHROOM FIXTURES,
BUILT IN KITCHEN CABINETS, BUILT IN WORK STATIONS, LIGHTING CONTROLERS,
BACK UP ELECTRICAL GENERATORS, TRANSFER SWITCHES AND ASSOCIATED CONTROLERS
FORKLIFTS/ORDER PICKERS (IF IDENTIFIED AS LEASED),
REFRIGERATION RACKS AND COMPRESSORS (FREON TO BE REMOVED BY LUCKY'S
NOT INCLUDED BUT NOT LIMITED TO:
OUTDOOR SIGNAGE, LIGHT FIXTURES, DISHWASHERS (LEASED), PRINTERS (LEASED),
ALL LEASEHOLD IMPROVEMENTS INCLUDING BUT NOT LIMITED TO:
A/C UNITS, PLUMBING, LIGHTING, FLOORING, FIRE SUPRESSION/SPRINKLER SYSTEMS,
BEFORE DISMANTLING).
ALL ITEMS MUST BE REMOVED BY 2-29-2020, UNLESS A LETTER FROM THE LANDLORD IS
PROVIDED STATING THAT ALL FF&E MAY REMAIN ON THE PREMESIS.
ALL ITEMS ARE SOLD AS IS WHERE IS, NO WARRANTIES EXPRESSED OR IMPLIED. REMOVAL IS THE BUYERS RESPONSIBILITY.
STORE#
STORE LOCATION
INVOICE # Calabasas, CA 91302
FF&E FROM LUCKY'S MARKET AT:
200 N HURSTBOURNE PKWY
LOUISVILLE, KY 40222
TERMS: 25% DUE ON RECEIPT, BALANCE DUE ON 2/7/2020
ALL REMOVABLE FF&E TO INCLUDE BUT NOT LIMITED TO:
ALL FF&E LOCATED INSIDE THE FACILITY, KITCHEN, BAKERY, SHOPPING CARTS,
DELI EQUIPMENT, REFRIGERATION EQUIPMENT, BALER, COMPACTOR,
POS SYSTEM, NETWORK EQUIPMENT, SERVER EQUIPMENT, DESKTOP COMPUTERS,
GONDOLA SHELVING, BUTCHER EQUIPMENT, CAFÉ EQUIPMENT, WALK IN COOLERS,
All items are sold “as-is”, with no warranties or guaranties, expressed or implied. Buyer is required to remove any item purchased hereunder and assumes any and all risks and
responsibilities associated with such removal, including , without limitation, the responsibility for providing licensed and bonded professionals to ensure proper water, gas and or/or
power disconnection, and full financial responsibility for any damage or liability to person or property resulting from any negligent act or omission of Buyer or any of Buyer’s
employees, agents, or representatives during pickup or removal. Buyer is solely responsible to provide any personnel, equipment or materials needed to pickup and remove all
purchased items, and in the event any item purchased contains hazardous materials, (e.g. Freon, etc.) Buyer shall provide evidence that Buyer or its representatives are licensed for
such removal and shall comply with all applicable local, state and federal rules, laws and regulations applicable thereto. Absolutely no al lowances are made for claims or shortages
once items have left the premises. Buyer may not abandon items purchased by Buyer and in the event Buyer does not remove the purchased assets in the manner and timeframe
indicated herein, Buyer shall be obligated to pay damages to Seller in the amount of $300 / day unless otherwise agreed.
BUYER HAS READ AND AGREES TO THESE AND ALL OTHER TERMS SET FORTH AS AN EXPRESSED CONDITION OF SALE.
Signed Date
I hereby certify that I am engaged in the business of selling ;
that the tangible personal property described therein which I hereby purchase from
Will be resold by me in the form of tangible persona property, provided, however, that in the event any such property is used for any purpose other than retention, demonstration, or
display while holding it for sale in the regular course of business. It is understood that I am required by State Sales and Use Tax Laws to report to and pay over to the appropriate
governmental authority, which tax is measured by the purchase of price of such property.
12LOU000052
12LOU000052
Case 20-10166-JTD Doc 807-6 Filed 06/18/20 Page 2 of 2
EXHIBIT G
Case 20-10166-JTD Doc 807-7 Filed 06/18/20 Page 1 of 14
Case 20-10166-JTD Doc 108 Filed 02/06/20 Page 1 of 13Case 20-10166-JTD Doc 807-7 Filed 06/18/20 Page 2 of 14
EXHIBIT A
Case 20-10166-JTD Doc 108 Filed 02/06/20 Page 2 of 13Case 20-10166-JTD Doc 807-7 Filed 06/18/20 Page 3 of 14
Served 1/28/2020Lucky's Market Parent Company, LLC, et al. - Service List to e-mail Recipients
5 STAR REFRIGERATION & AIR CONDITIONING [email protected]
7978 ASSOCIATES [email protected]
BALLARD SPAHR LLPLESLIE [email protected]
BALLARD SPAHR LPLAUREL [email protected]
BENDERSON [email protected]
BENDERSON PROPERTIES [email protected]
BRNK BRADENTON [email protected]
BUNZL HOLDINGS, [email protected]
CAITO FOODS [email protected]
CAPTIVEAIRE SYSTEMS [email protected]
CARDLYTICS [email protected]
CHARLIES [email protected]
CONIS DEVELOPMENT [email protected]
CONIS [email protected]
CROSSET COMPANY [email protected]
DANIA LIVE [email protected]
DANIA LIVE 1748, [email protected]
DANIA LIVE 1748, [email protected]
DANIA LIVE 1748, [email protected]
DIXIT PROPERTIES [email protected]
GLADES 95TH LLCBRIAN [email protected]
GLADES 95TH [email protected]
GLOBAL AXIOM, [email protected]
GOURMET FOODS [email protected]
GUNBARREL PROPERTIES [email protected]
HALIFAX ASSOCIATES [email protected]
HARVEST MEAT COMPANY [email protected]
HAWKINS [email protected]
HORN INVESTMENT [email protected]
HUSSMANN [email protected]
J RAYMOND CONSTRUCTION [email protected]
JDA SOFTWARE [email protected]
KIMCO-PETERS CO [email protected]
KPS GLOBAL [email protected]
MONZACK MERSKY MCLAUGHHLIN & BROWDER, P.ABRIAN J. [email protected]
MONZACK MERSKY MCLAUGHHLIN & BROWDER, P.A.RACHEL B. [email protected]
NEELANDS USA [email protected]
NEPTUNE BEACH FL REALTY [email protected]
NORTH DIXIE CENTER [email protected]
OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY [email protected]
Page 1 of 2
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OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY [email protected]
OFFICE OF THE ATTORNEY GENERAL [email protected]
OFFICE OF THE U.S. TRUSTEETIMOTHY J [email protected]
PINELOCH CENTER STREET [email protected]
PINELOCH CENTER STREET [email protected]
POLSINELLI, PCCHRIS [email protected]
QUADRANT WHEAT RIDGE [email protected]
REALTY INCOME PROPERTIES [email protected]
RICHARDS, LAYTON & FINGER, P.A.BRETT M. [email protected]
RICHARDS, LAYTON & FINGER, P.A.ZACHARY I. [email protected]
RIVER BAY PLAZA BH [email protected]
RIVER BAY PLAZA BH [email protected]
SB-VETS-1MICHAEL J. [email protected]
SCHMID [email protected]
SEASONS-4 [email protected]
SHERWOOD FOOD [email protected]
SIESTA RETAIL [email protected]
SNYDER CONSTRUCTION [email protected]
TALLAHASSEE WEST TENNESSEE [email protected]
TRUNO RETAIL TECHNOLOGY [email protected]
UNITED STATES ATTORNEY'S [email protected]
WASHINGTON PRIME [email protected]
WEIL, GOTSHAL & MANGES LLPGARRET A. [email protected]
WEIL, GOTSHAL & MANGES LLPMOSHE A. [email protected]
WEINGARTEN REALTY [email protected]
WOOLBRIGHT WEKIVA [email protected]
Parties Served: 77
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EXHIBIT B
Case 20-10166-JTD Doc 108 Filed 02/06/20 Page 5 of 13Case 20-10166-JTD Doc 807-7 Filed 06/18/20 Page 6 of 14
Served 1/28/2020Lucky's Market Parent Company, LLC, et al. - U.S. Mail
1916 LLCPRESIDENT/LEGAL DEPARTMENT1375 WALNUTBOULDER CO 80302
425SC, LLCPRESIDENT/LEGAL DEPARTMENT2725 ROCKY MOUNTAIN AVE 200DENVER CO 80538
5 STAR REFRIGERATION & AIR CONDITIONING INCATTN: JOSEPH E MATTHEWS23091 CORTEZ BLVDBROOKSVILLE, FL 34601
7978 ASSOCIATES VII, LLC (BENDERSON)PRESIDENT/LEGAL DEPARTMENT7978 COOPER CREEK BLVDUNIVERSITY PARK FL 34201
ALACHUA COUNTY SHERIFF'S OFFICELEGAL DEPARTMENT2621 SEAST HAWTHORNE RDGAINESVILLE FL 32641
ALACHUA COUNTY TAX COLLECTORLEGAL DEPARTMENT12 SE 1ST STCOUNTY ADMIN BUILDINGGAINESVILLE FL 32601
AMERICAN REALTY CAPITALPRESIDENT/LEGAL DEPARTMENT405 PARK AVENUE, 14TH FLOORRE: ARC CLORLFL001NEW YORK NY 10022
AMERICAN ZURICH INSURANCE COMPANY1299 ZURICH WAYSCHAUMBURG, IL 60196-1056
ARGONAUT GREAT CENTRAL INSURANCE COMPAN225 W WASHIGNTON ST, 24TH FLCHICAGO, IL 60606
ARGONAUT INSURANCE COMPANY225 W WASHIGNTON ST, 24TH FLCHICAGO, IL 60606
ATA FORUM LOUISVILLE KY LLCPRESIDENT/LEGAL DEPARTMENT2720 E CAMELBACK RDPHOENIX AZ 85016
BAY COUNTY TAX COLLECTORLEGAL DEPARTMENT850 W 11TH STPANAMA CITY FL 32401
BBIF SUBSIDIARY CDE 3, LLCC/O BLACK BUSINESS INVESTMENT FUND, INCATTN: INEZ LONG301 E PINE ST, STE 175ORLANDO, FL 32801
BEAZLEY GROUP30 BATTERSON PARK RDFARMINGTON, CT 06032
BENDERSON PROPERTIES, INC & DONALD ROBINSDONALD ROBINSON7978 COOPER CREEK BLVDSUITE 100UNIVERSITY PARK FL 34201
BENDERSON PROPERTIES, INC WR-I ASSOCIATES LTDPRESIDENT/LEGAL DEPARTMENT7978 COOPER CREEK BLVDUNIVERSITY PARK FL 34201
BLACKFOX PARKWAY ASSOCIATES LLCPRESIDENT/LEGAL DEPARTMENT825 DELAWARE AVELONGMONT CO 80501
BLUESOHOC/O QUAD/GRAPHICS, INCATTN: DAVE HONANN61 W23044 HARRYS WAYSUSSEX, WI 53089
BOONE COUNTY COLLECTOR OF REVENUELEGAL DEPARTMENT801 E WALNUT ST, STE 118COLUMBIA MO 65201
BOULDER COUNTY PUBLIC HEALTHFOOD SAFETY PROGRAM3450 BROADWAYBOULDER CO 80304-1899
BOULDER COUNTY TREASURERLEGAL DEPARTMENT1325 PEARL ST, STE 5BOULDER CO 80302
BRE MARINER HUNTERS CREEK, LLCPRESIDENT/LEGAL DEPARTMENT450 LEXINGTON AVEFLOOR 13NEW YORK NY 10017
BREVARD COUNTY TAX COLLECTORLEGAL DEPARTMENT400 S ST, 6TH FLTITUSVILLE FL 32780
BRNK BRADENTON LLCPRESIDENT/LEGAL DEPARTMENT11611 SAN VICENTE BLVDLOS ANGELES CA 90049
BROWARD COUNTY TAX COLLECTORLEGAL DEPARTMENT1800 NW 66TH AVE, STE 101FORT LAUDERDALE FL 33313
BUFFALO RIDGE CENTER SOUTH LLCPRESIDENT/LEGAL DEPARTMENT21 E LONG LAKE RDBLOOMFIELD HILLS MI 48304
BUNZL HOLDINGS, INC.ATTN: JIM MCCOOL1 CITYPLACE DR, STE 200ST. LOUIS, MO 63141
CAITO FOODS SERVICEATTN: DAVE COCHRAN3120 N POST RDINDIANAPOLIS, IN 46226
CAPTIVEAIRE SYSTEMS INCATTN: BOB LUDDY4641 PARAGON PARK RDRALEIGH, NC 27616
CARDLYTICS INCATTN: SCOTT GRIMES675 PONCE DE LEON AVE NE, STE 6000ATLANTA, GA 30308
CASTO SEAST REALTY SERVICES LLCPRESIDENT/LEGAL DEPARTMENT5391 LAKEWOOD RANCH BLVD., SUITE 100RE: LUCAS CLERMONT LIMITED PARTNERSHIPSARASOTA FL 34240
CHARLIES PRODUCEATTN: DWAYNE WILSON4103 2ND AVE SSEATTLE, WA 98134
CHARTER TOWNSHIP OF GARFIELDLEGAL DEPARTMENT3848 VETERANS DRTRAVERSE CITY MI 49684
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CHATAM COUNTYLEGAL DEPARTMENT222 W OGLETHORPE AVE, STE 107SAVANNAH GA 31401
CITY AND COUNTY OF DENVERLEGAL DEPARTMENT201 W COLFAX AVEDENVER CO 80202
CITY OF ANN ARBORLEGAL DEPARTMENT301 E HURON STFIFTH FLANN ARBOR MI 48104
CITY OF BILLINGSLEGAL DEPARTMENT210 N 27TH STBILLINGS MT 59101
CITY OF BOULDERLEGAL DEPARTMENT1777 BROADWAYBOULDER CO 80302
CITY OF CLERMONT FLORIDALEGAL DEPARTMENTBUSINESSTAX685 W MONTROSE STCLERMONT FL 34711
CITY OF CLEVELANDLEGAL DEPARTMENT601 LAKESIDE AVEROOM 127CLEVELAND OH 44114-1085
CITY OF COLUMBIALEGAL DEPARTMENT701 E BROADWAY, FIFTH FLCOLUMBIA MO 65201
CITY OF COLUMBUSLEGAL DEPARTMENT77 N FRONT STCOLUMBUS OH 43215
CITY OF CORAL SPRINGSLEGAL DEPARTMENT9500 W SAMPLE RDCORAL SPRINGS FL 33065
CITY OF FORT COLLINSLEGAL DEPARTMENT215 N MASON STFORT COLLINS CO 80524
CITY OF GAINESVILLELEGAL DEPARTMENT200 E UNIVERSITY AVEGAINESVILLE FL 32601
CITY OF LONGMONTLEGAL DEPARTMENT350 KIMBARK STLONGMONT CO 80501
CITY OF LOUISVILLELEGAL DEPARTMENT617 W JEFFERSON STLOUISVILLE KY 40202
CITY OF LYNDONLEGAL DEPARTMENT515 WOOD RDLYNDON KY 40222
CITY OF NEPTUNE BEACH FLORIDALEGAL DEPARTMENT116 1ST STNEPTUNE BEACH FL 32266
CITY OF OAKLAND PARK FLORIDALEGAL DEPARTMENT5399 N DIXIE HWY, STE 3OAKLAND PARK FL 33334
CITY OF ORLANDOLEGAL DEPARTMENTCASHIERS OFFICE400 S ORANGE AVE, 1ST FLORLANDO FL 32802
CITY OF ORMOND BEACHLEGAL DEPARTMENT22 S BEACH STP.O. BOX 277ORMOND BEACH FL 32175
CITY OF ORMOND BEACHLEGAL DEPARTMENTP.O. BOX 217OMOND BEACH FL 32175-0217
CITY OF PANAMA CITYLEGAL DEPARTMENTCITY HALL501 HARRISON AVEPANAMA CITY FL 32401
CITY OF PLANTATIONLEGAL DEPARTMENT400 NW 73RD AVEPLANTATION FL 33317
CITY OF PLANTATION FLLEGAL DEPARTMENTUTILITIES DEPTP.O. BOX 31132TAMPA FL 33631-3132
CITY OF ROCK HILL MISSOURILEGAL DEPARTMENTBUSINESS LICENSE APPLICATION320 W THORNTON AVEROCK HILL MO 63119
CITY OF SARASOTALEGAL DEPARTMENT1761 12TH STSARASOTA FL 34236
CITY OF SAVANNAHLEGAL DEPARTMENT2 E BAY STP.O. BOX 1027SAVANNAH GA 31401
CITY OF SAVANNAHLEGAL DEPARTMENT305 FAHM STP.O. BOX 1228SAVANNAH GA 31402
CITY OF SPRINGFIELDLEGAL DEPARTMENT840 BOONVILLE AVE, 1ST FLSPRINGFIELD MO 65802
CITY OF ST PETERSBURGLEGAL DEPARTMENT325 CENTRAL AVEST. PETERSBURG FL 33701
CITY OF ST PETERSBURGLEGAL DEPARTMENTCENTRAL CASHIERSP.O. BOX 2842ST PETERSBURG FL 33731
CITY OF ST PETERSBURGLEGAL DEPARTMENTP.O. BOX 33034ST PETERSBURG FL 33733-3034
CITY OF WEST MELBOURNE FLORIDALEGAL DEPARTMENT2240 MINTON RDWEST MELBOURNE FL 32904
CITY OF WHEAT RIDGELEGAL DEPARTMENT7500 W 29TH AVEWHEAT RIDGE CO 80033
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COLLIER COUNTYLEGAL DEPARTMENTCOUNTY COURT HOUSE3291 TAMIAMI TRAIL ENAPLES FL 34112
COLORADO DEPARTMENT OF AGRICULTURELEGAL DEPARTMENTINSPECTION AND CONSUMER SERVICES DIV305 INTERLOCKEN PKWYBROOMFIELD CO 80021
COLORADO DEPARTMENT OF REVENUELEGAL DEPARTMENT1375 SHERMAN STDENVER CO 80203
COLUMBUS CITY TREASURERLEGAL DEPARTMENT4252 GROVES RDCOLUMBUS OH 43232
COLUMBUS PUBLIC HEALTH DEPARTMENTLEGAL DEPARTMENT240 PARSONS AVECOLUMBUS OH 43215
COMMONWEALTH OF KENTUCKYLEGAL DEPARTMENTDEPARTMENT OF ALCOHOLIC BEVERAGE CONTRO1003 TWILIGHT TRAILFRANKFORT KY 40601-8400
CONIS DEVELOPMENT COPRESIDENT/LEGAL DEPARTMENT2285 FOREST AVEBOULDER CO 80304
CONIS DEVELOPMENT COPRESIDENT/LEGAL DEPARTMENT2885 FOREST AVEBOULDER CO 80304
CONIS INCPRESIDENT/LEGAL DEPARTMENT3990 BROADWAYBOULDER CO 80304
CORE SYCAMORE TOWN CENTER LLCPRESIDENT/LEGAL DEPARTMENT1600 SYCAMORE STIOWA CITY IA 52240
CREIGHTON CONSTRUCTION MANAGEMENTATTN: M DAN CREIGHTON900 SW PINE ISLAND RD, STE 202CAPE CORAL, FL 33991
CROSSET COMPANY LLCATTN: GREG KURKJIAN10295 TOEBBEN DRINDEPENDENCE, KY 41051
DALE COMPANY LLCPRESIDENT/LEGAL DEPARTMENT8902 N DALE MABRY HWYTAMPA FL 33614
DANIA LIVE 1748, LLCC/O KIMCO REALTY CORPORATIONATTN: GARY BAZYDLO500 N BROADWAY, STE 201JERICHO, NY 11753
DANIA LIVE 1748, LLCC/O KIMCO REALTY CORPORATIONATTN: KARAN OSTERHOUT6060 PIEDMONT ROW DR S, STE 200CHARLOTTE, NC 28287
DANIA LIVE 1748, LLCPRESIDENT/LEGAL DEPARTMENT500 N BROADWAY, SUITE 201PO BOX 9010JERICHO NY 11753
DDR KM SHOPPING CENTER LLCPRESIDENT/LEGAL DEPARTMENT330 ENTERPRISE PKWYBEACHWOOD OH 44122
DDRTC CYPRESS TRACE LLCPRESIDENT/LEGAL DEPARTMENT3300 ENTERPRISE PKWYBEACHWOOD OH 44122
DELAWARE SECRETARY OF STATELEGAL DEPARTMENT401 FEDERAL ST, STE 4DOVER DE 19901
DIXIT PROPERTIES LLCPRESIDENT/LEGAL DEPARTMENT5300 W CYPRESS STTAMPA FL 33607
DUVAL COUNTY TAX COLLECTORLEGAL DEPARTMENT231 E FORSYTH STJACKSONVILLE FL 32202
EBP 2800 NORTH HIGH LLCPRESIDENT/LEGAL DEPARTMENT4300 E 5TH AVEPO BOX 24550COLUMBUS OH 43219
FAYETTE COUNTY, KENTUCKYLEGAL DEPARTMENT200 E MAIN STLEXINGTON KY 40507
FLORIDA DEPARTMENT OF REVENUELEGAL DEPARTMENT5050 W TENNESSEE STTALLAHASSEE FL 32399-0100
FLORIDA DEPARTMENT OF STATELEGAL DEPARTMENTCLIFTON BLDG, FICTITIOUS NAME REGISTATION2661 EXEC CENTER CIRTALLAHASSEE FL 32301
FLORIDA DEPT OF AGRICULTURE AND CONSUMER SELEGAL DEPARTMENTREVENUE PROCESSING SECTION407 S CALHOUN ST, RM 131TALLAHASSEE FL 32399-0800
FLORIDA DEPT OF BUSINESS AND PROFESSIONAL LEGAL DEPARTMENTDIVISION OF ALCOHOLIC BEVERAGES AND TOBACC2601 BLAIR STONE RDTALLAHASSEE FL 32399-1023
FLORIDA FISH & WILDLIFE CONSERVATION COMMISSILEGAL DEPARTMENTOFFICE OF LICENSING AND PERMITTINGP.O. BOX 6150TALLAHASSEE FL 32314-6150
FORT COLLINS DEPARTMENT OF REVENUELEGAL DEPARTMENT215 N MASON STFORT COLLINS CO 80524
GBT REALTY CORPPRESIDENT/LEGAL DEPARTMENT9010 OVERLOOK BLVDRE: TAMIAMI INVESTMENT PARTNERSBRENTWOOD TN 37207
GEORGIA DEPARTMENT OF AGRICULTURELEGAL DEPARTMENTP.O. BOX 742612ATLANTA GA 30374-2612
GEORGIA DEPARTMENT OF REVENUELEGAL DEPARTMENT1800 CENTURY BLVD NEASTATLANTA GA 30345
GLADES 95TH LLCC/O SCHMIER PROPERTY GROUP, INCATTN: BRIAN SCHMIER2200 BUTTS RD, STE 300BOCA RATON, FL 33431
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GLENSTONE MARKETPLACE LLCPRESIDENT/LEGAL DEPARTMENTP.O. BOX 39709 HWY 28 WBELLE MO 65013
GLL REAL ESTATE PARTNERSBRANDON BENSON200 S ORANGE AVE., SUITE 137RE: GLL SELECTION II FLORIDA LPORLANDO FL 32801
GLOBAL AXIOM, INC.ATTN: TIM YOST295 LAFAYETTE ST, STE 700NEW YORK, NY 10012
GOURMET FOODS INTERNATIONALATTN: BRIAN SCOTT255 TED TURNER DR SWATLANTA, GA 30303
GREAT AMERICAN INSURANCE COMPANY301 E 4TH ST, 24TH FLCINCINNATI, OH 45202
GREENE COUNTY COLLECTOR OF REVENUELEGAL DEPARTMENT940 N BOONVILLE AVESPRINIGFIELD MO 65802
GRIFFIN FARM AT MIDTOWN II, LLCPRESIDENT/LEGAL DEPARTMENT7490 VIA DELLAGIO WAYORLANDO FL 32819
GUNBARREL PROPERTIES LLCPRESIDENT/LEGAL DEPARTMENT864 W S BOULDER RDLOUISVILLE CO 80027
HALIFAX ASSOCIATES LLCPRESIDENT/LEGAL DEPARTMENT3948 3RD ST S, 311JACKSONVILLE BEACH FL 32250
HALPERNS STEAK & GARYS SEAFOODATTN: RAY HICKS4685 WELCOME ALL RDATLANTA, GA 30349
HARVEST MEAT COMPANY INCATTN: JAY LEAVY1022 BAY MARINA DR, STE 106NATIONAL CITY, CA 91950
HAWKINS CONSTRUCTIONATTN: JOHN MCCAUGHERTY1430 L AND R INDUSTRIAL BLVDTARPON SPRINGS, FL 34689
HORN INVESTMENT COPRESIDENT/LEGAL DEPARTMENTPO BOX 2806JACKSON WY 83001
HUSSMANN CORPORATIONATTN: CATHEY HAIGH12999 SAINT CHARLES ROCK RDBRIDGETON, MO 63044
INDIANA DEPARTMENT OF REVENUELEGAL DEPARTMENT100 N SENATE AVEINDIANAPOLIS IN 46204
INDIANA SECRETARY OF THE STATELEGAL DEPARTMENT200 W WASHINGTON ST, RM 201INDIANAPOLIS IN 46204
INTERNAL REVENUE SERVICECENTRALIZED INSOLVENCY OPERATIONP.O. BOX 7346PHILADELPHIA, PA 19101-7346
INTERNAL REVENUE SERVICELEGAL DEPARTMENTINTERNAL REVENUE SERVICEOGDEN UT 84201-0009
IOWA DEPARTMENT OF REVENUELEGAL DEPARTMENT1305 E WALNUT ST, 4TH FLDES MOINES IA 50319
IRT PARTNERS L.P.PRESIDENT/LEGAL DEPARTMENT1 INDEPENDENT DRJACKSONVILLE FL 32202
J C LEWIS INVESTMENT COMPANY LLCPRESIDENT/LEGAL DEPARTMENT9505 ABERCORN STSAVANNAH GA 31406
J RAYMOND CONSTRUCTION CORPATTN: TOM BORGIA465 W WARREN AVELONGWOOD, FL 32750
JDA SOFTWARE INCATTN: GIRISH RISHI15059 NORTH SCOTTSDALE, STE 400SCOTTSDALE, AZ 85254
JEFFERSON COUNTYLEGAL DEPARTMENT100 JEFFERSON COUNTY PKWYGOLDEN CO 80419
JEFFERSON COUNTYLEGAL DEPARTMENT531 COURT PL, SUITE 604LOUISVILLE KY 40202
KENTUCKY DEPARTMENT OF REVENUELEGAL DEPARTMENT501 HIGH STFRANKFORT KY 40601
KENTUCKY DEPARTMENT OF REVENUELEGAL DEPARTMENTSTATION 67P.O. BOX 181FRANKFORT KY 40602-0181
KENTUCKY DEPT OF AGRICULTURELEGAL DEPARTMENTDIVISION OF REGULATION AND INSPECTION107 CORPORATE DRFRANKFORT KY 40601
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KPS GLOBAL LLCATTN: MIKE EAKINS4201 N BEACH STFORT WORTH, TX 76137
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LAKE COUNTY FLORIDALEGAL DEPARTMENT320 W MAIN STTAVARES FL 32778
LARIMER COUNTYLEGAL DEPARTMENT200 W OAK STFORT COLLINS CO 80521
LARIMER COUNTY DEPARTMENT OF HEALTH AND ELEGAL DEPARTMENT1525 BLUE SPRUCE DRFORT COLLINS CO 80524
LEON COUNTY TAX COLLECTORLEGAL DEPARTMENTP.O. BOX 1835TALLAHASSEE FL 32302
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MARKET AT MCKNIGHT I LLCPRESIDENT/LEGAL DEPARTMENT20 ALLEN AVEWEBSTER GROVES MO 63119
MICHIGAN DEPARTMENT OF AGRICULTURELEGAL DEPARTMENT525 W ALLEGAN STLANSING MI 48933
MICHIGAN DEPARTMENT OF TREASURYLEGAL DEPARTMENT701 S ELMWOOD AVETRAVERSE CITY MI 49684
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NAPLES COMMERCIAL MANAGEMENT LLCPRESIDENT/LEGAL DEPARTMENT8902 N DALE MABRY HWYTAMPA FL 33614
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ORANGE COUNTYLEGAL DEPARTMENTP.O. BOX 545100ORLANDO FL 32854
PIC WALNUT PARK LLCPRESIDENT/LEGAL DEPARTMENT4101 SIERRA DRBLOOMINGTON IN 47403
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PINELLAS COUNTY TAX COLLECTORLEGAL DEPARTMENT1800 66TH ST NST. PETERSBURG FL 33710
PINELOCH CENTER STREET LLCATTN: HEATHER COONS8998 GLADIN CTORLANDO, FL 32819
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PUBLIC HEALTH DEPARTMENT OF COLUMBIALEGAL DEPARTMENT1005 W WORLEY STCOLUMBIA MO 65203
QUADRANT WHEAT RIDGE CORNERS, LLCPRESIDENT/LEGAL DEPARTMENT353 MARSHALL AVEST LOUIS MO 63119
REALTY INCOME PROPERTIES 4, LLCPRESIDENT/LEGAL DEPARTMENT11995 EL CAMINO REALSAN DIEGO CA 92130
RIVER BAY PLAZA BH LLCPRESIDENT/LEGAL DEPARTMENT1274 49TH STBROOKLYN NY 11219
ROCKPORT NAPLES LLCPRESIDENT/LEGAL DEPARTMENT8902 N DALE MABRY HWYTAMPA FL 33614
SAMCO PROPERTIES LTDPRESIDENT/LEGAL DEPARTMENT6190 COCHRAN RDSOLON OH 44139
SARASOTA COUNTYLEGAL DEPARTMENT101 S WASHINGTON BLVDSARASOTA FL 34236-6993
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ST. LOUIS COUNTYLEGAL DEPARTMENT41 S CENTRAL AVEST. LOUIS MO 63105-1799
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VERDE PLAZA LLCPRESIDENT/LEGAL DEPARTMENT8650-12 OLD KINGS RD SJACKSONVILLE FL 32217
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YELLOWSTONE COUNTY TREASURERLEGAL DEPARTMENT217 N 27TH ST, RM 108COUNTY COURTHOUSEBILLINGS MT 59101
Parties Served: 256
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EXHIBIT H
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73925279.1
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: LUCKY’S MARKET PARENT COMPANY, LLC, et al.,1
Debtors.
Chapter 11 Case No. 20-10166 (JTD) (Jointly Administered) Re: Docket Nos.
DECLARATION OF DENNIS JENKINS IN SUPPORT OF THE
OBJECTION OF THE DEBTORS TO ATA FORUM LOUISVILLE KY, LLC’S APPLICATION FOR ALLOWANCE OF ADMINISTRATIVE CLAIMS
UNDER 11 U.S.C. §§ 105, 503(b), AND 365(d)(3)
Pursuant to 28 U.S.C. § 1764, Dennis Jenkins, declares as follows under the penalty of
perjury:
1. I am an independent Liquidation Consultant who has worked with Great American
Global Partners, LLC (“Great American” or the “Liquidation Consultant”) for the last 14 years.
2. Great American was hired by the Debtors to assist with the sale of furniture,
fixtures, and equipment (“FF&E”) for certain of the Debtors’ stores.
3. I was contracted by Great American to help oversee the Debtors’ going out of
business sales.
1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are Lucky’s Market Parent Company, LLC (2055), Lucky’s Farmers Market Holding Company, LLC (5480), Lucky’s Market Operating Company, LLC (7064), LFM Stores LLC (3114), Lucky’s Farmers Market, LP (0828), Lucky’s Farmers Market Resource Center, LLC (7711), Lucky’s Market Holding Company 2, LLC (0607), Lucky’s Market GP 2, LLC (9335), Lucky’s Market 2, LP (8384), Lucky’s Market of Longmont, LLC (9789), Lucky’s Farmers Market of Billings, LLC (8088), Lucky’s Farmers Markets of Columbus, LLC (3379), Lucky’s Farmers Market of Rock Hill, LLC (3386), LFM Jackson, LLC (8300), Lucky’s Farmers Market of Ann Arbor, LLC (4067), Lucky’s Market of Gainesville, LLC (7877), Lucky’s Market of Bloomington, LLC (3944), Lucky’s Market of Plantation, LLC (4356), Lucky’s Market of Savannah, GA, LLC (1097), Lucky’s Market of Traverse, City, LLC (2033), Lucky’s Market of Naples, FL, LLC (8700), Sinoc, Inc. (0723), Lucky’s Farmers Market of Ellisville, LLC (2875), and Lucky’s Farmers Market of Lexington, KY, LLC (3446).
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73925279.1
4. I submit this declaration (this “Declaration”) in support of the Objection of the
Debtors to ATA Forum Louisville KY, LLC’s Application for Allowance of Administrative Claims
under 11 U.S.C. §§ 105, 503(b), and 365(d)(3) (the “Motion”).2
5. Great American marketed the Debtors’ FF&E online through social media as well
as by cold calling local companies and contacting dealers all over the country.
6. There was only one bulk bid for the Louisville FF&E as most dealers did not want
the Louisville FF&E because of its age and condition. Chad Renier of Mechanical Removal &
Relocation, LLC (the “Buyer”) submitted the sole bid.
7. Buyer agreed to buy the Louisville FF&E for the purchase price of $20,000,
evidenced by that certain Invoice #80015, a true and correct copy of which is attached to the
Motion as Exhibit F (the “FF&E Invoice”).
8. Great American also located buyers for certain of the Louisville FF&E not included
in the FF&E Invoice, which resulted in collective sales of about $5,000.
9. Great American hired an independent contractor, Clarissa Mclean, to oversee the
sale and removal of the Louisville FF&E in person. Great American has worked with Ms. Mclean
on at least three other store liquidations.
10. On or about February 6, 2020, the Buyer’s crew arrived at the Louisville Store for
their initial review of the Louisville FF&E. Ms. Mclean was present and supervised the Buyer’s
team.
11. Over the next few days, the Buyer’s crew proceeded to package all small appliances
and disassemble equipment that was located behind areas that were inaccessible to the public.
Once the Freon for the refrigeration was pumped out, Buyer’s crew then proceeded to prepare the
2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Motion.
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73925279.1
refrigeration cases for removal. On each of these days, Ms. Mclean was present and supervised the
Buyer’s team.
12. On each of February 10, 11, and 12, Ms. Mclean unlocked the store and was present
and supervised the Buyer’s team.
13. As of February 12, 2020, none of the Louisville FF&E had been removed.
14. On February 12, 2020, the Buyer arrived at the Louisville Store to commence
removal of the Louisville FF&E. After Buyer unloaded forklifts and heavy equipment, Ms. Mclean
called me to report that she received a phone call from Jeremy Hamilton, who introduced himself
as the property manager on behalf of Landlord. Ms. Mclean informed me that Mr. Hamilton
ordered Ms. Mclean to stop any further removal immediately. Mr. Hamilton also informed Ms.
Mclean that he was sending a representative with the sheriff to stop all removal.
15. Ms. Mclean also informed me that a second representative of the Landlord arrived
at the Louisville Store with a locksmith to change the locks and that both this second representative
and Mr. Hamilton asserted that Landlord owned the equipment and that the Buyer and Great
American were trespassing.
16. Ms. Mclean informed me that the Landlord was going to send a representative to
the Louisville Store the next day to oversee the FF&E removal. I agreed to inform the Debtors that
the FF&E removal would be postponed until February 13, 2020 to allow the Landlord’s
representative to be onsite to oversee the removal process.
17. On February 13, 2020, Ms. Mclean called me to inform me that the Landlord
representative never showed.
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73925279.1
18. On February Friday 14, 2020, Ms. Mclean called me to inform me that the Landlord
representative never showed despite having already sent a representative two days earlier to halt
the removal of the Louisville FF&E.
19. Ms. Mclean informed me late that afternoon that the Landlord’s representative
would not arrive until sometime on February 18, 2020. I informed her that I was reaching out to
Debtors’ counsel.
20. Around 6:30 p.m. eastern on February 14, 2020, I informed Ms. Mclean that the
Debtors and their professionals authorized the Buyer to commence removal of the personalty and
Louisville FF&E. I also informed Buyer.
21. On February 15, 2020 and February 17, 2020, Buyer and his crew were at the
Louisville Store packaging FF&E for removal and hauling scrap to the scrap yard.
22. Around noon on Tuesday, February 18, 2020, Ms. Mclean called me to inform me
that Mr. Hamilton arrived at the Louisville Store and demanded the Buyer stop his removal of the
Louisville FF&E. Mr. Hamilton threatened to call the police to arrest Ms. Mclean. I told her to
leave the premises and to inform Buyer to leave as well.
23. As a result of Mr. Hamilton’s threats and demands, Ms. Mclean was forced to leave
the Louisville Store. Buyer and his crew were forced out of the store as well. Buyer was unable to
load most of the FF&E, and he was unable to finish the cleanup of the Louisville Store.
Executed this 17th of day of June, 2020.
/s/ Dennis Jenkins Great American Global Partners, LLC Liquidation Consultant to the Debtors
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