Case 20-32181-KLP Doc 758 Filed 08/13/20 Entered 08/13/20 13:37:05 Desc Main Document Page 1 of 7 Stephen A. Metz (VA Bar No. 89738) Offit Kurman, P.A. 4800 Montgomery Lane, 9th Floor Bethesda, MD 20814 Tel.: (240) 507-1723 | Fax: (240) 507-1735
[email protected] Counsel to Simon Property Group, Inc. and affiliates UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION ------------------------------------------------------------ x : In re : Chapter 11 : CHINOS HOLDINGS, INC., et al., : Case No. 20–32181 (KLP) : Debtors.1 : (Jointly Administered) : ------------------------------------------------------------ x LIMITED OBJECTION AND RESERVATION OF RIGHTS OF SIMON PROPERTY GROUP, INC. TO DEBTORS’ NOTICE OF ASSUMPTION OR ASSIGNMENT AND CURE COSTS RELATING TO EXECUTORY CONTRACTS AND UNEXPIRED LEASES OF THE DEBTORS Simon Property Group, Inc. and its affiliates (“Simon”), by its undersigned counsel respectfully files this Limited Objection and Reservation of Rights with respect to the Debtors’ Notice of Assumption or Assignment and Cure Costs Relating to Executory Contracts and Unexpired Leases of the Debtors [Docket No. 667] (the “Cure Notice”), and in support thereof states as follows: 1. On May 4, 2020 (the “Petition Date”), Chinos Holdings, Inc. and its debtor affiliates (collectively, “Debtors”) filed a voluntary petition for relief under Chapter 11 of the United States Bankruptcy Code, 11 U.S.C. §101, et seq. (the “Bankruptcy Code”), thereby commencing Case No. 20- 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, as applicable, are Chinos Holdings, Inc. (3834); Chinos Intermediate Holdings A, Inc.