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MS Management Associates Case 20-33332-KLP Doc 838 Filed 01/25/21 Entered 01/25/21 21:06:08 Desc Main Document Page 1 of 4 Brian S. Hermann (pro hac vice to be submitted) Alexander Woolverton (pro hac vice to be submitted) PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, New York 10019 Telephone: (212) 373-3000 Facsimile: (212) 757-3990 Email: [email protected] [email protected] Christian K. Vogel (Va. Bar No. 75537) Vogel & Cromwell, LLC 513 Forest Ave., Suite 205 Richmond, Virginia 23229 Telephone: (804) 728-1574 Email: [email protected] Counsel to M.S. Management Associates, Inc. and Its Affiliates UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION ------------------------------------------------------ x : In re: : Chapter 11 : LE TOTE, INC., et al.,1 : Case No. 20-33332 (KLP) : Vogel & Debtors. : (Jointly Administered) Cromwell, L.L.C. : ------------------------------------------------------ x NOTICE OF APPEARANCE PURSUANT TO BANKRUPTCY RULE 9010 AND REQUEST FOR NOTICES PLEASE TAKE NOTICE THAT the undersigned counsel enters their appearance pursuant to 11 U.S.C. § 1109(b), Fed. R. Bankr. P. 9010 and Local Bankruptcy Rule 9010-1 on 1 A complete list of each of the Debtors in these chapter 11 cases may be obtained on the website of the Debtors’ claims and noticing agent at http://cases.stretto.com/letote. The location of the Debtors’ service address in these chapter 11 cases is 250 Vesey Street, 22nd Floor, New York, New York 10281. Case 20-33332-KLP Doc 838 Filed 01/25/21 Entered 01/25/21 21:06:08 Desc Main Document Page 2 of 4 behalf of M.S. Management Associates, Inc. and certain of its affiliates, including King of Prussia Associates, Walt Whitman Mall, LLC, Livingston Mall Venture, Quaker Bridge Mall, LLC, Woodfield Mall LLC, Bellwether Properties of Massachusetts, L.P., Braintree Property Associates, L.P., and Rockaway Center Associates (collectively, “Simon”), parties in interest and creditors herein, and request that copies of all notices, pleadings and papers filed in this case be served on the following via mail, hand delivery, facsimile, electronically, or other appropriate means at the addresses indicated below: Brian S. Hermann (pro hac vice to be submitted) Alexander Woolverton (pro hac vice to be submitted) PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, New York 10019 Telephone: (212) 373-3000 Facsimile: (212) 757-3990 Email: [email protected] [email protected] Christian K. Vogel Vogel & Cromwell, L.L.C. 513 Forest Ave., Suite 205 Richmond, Virginia 23229 804.728.1574 804.728.1625 (facsimile) Vogel & [email protected] Cromwell, L.L.C. PLEASE TAKE FURTHER NOTICE that the foregoing request includes not only the notices and paper specified above, but also includes, without limitation, any orders and notices of any application, order, notice, motion, petition, pleading, request, disclosure statement, plan, complaint or demand, whether formal or informal, whether written or oral, and whether transmitted or conveyed by mail, delivery, electronically, telephone, facsimile or otherwise, 2 Case 20-33332-KLP Doc 838 Filed 01/25/21 Entered 01/25/21 21:06:08 Desc Main Document Page 3 of 4 which affect the Debtors, property of the Debtors, or any rights or interest of creditors and parties in interest in this bankruptcy case. PLEASE TAKE FURTHER NOTICE that this Notice of Appearance Pursuant to Bankruptcy Rule 9010 and Request for Notices shall not be deemed or constructed to be a waiver of Simon’s rights (1) to have final orders entered only after de novo review by a District Judge; (2) to trial by jury in any proceeding so triable in this case or any case, controversy, or proceeding arising in or related to this case, (3) to have the District Court withdraw the reference in any matter subject to mandatory or discretionary withdrawal, or (4) any other rights, claims, actions, defenses, setoffs, or recoupments to which Simon is or may be entitled, in law or equity, including without limitation any rights under any arbitration provisions, all of which rights, claims, actions, defenses, setoffs, and recoupments Simon expressly reserves. M.S. MANAGEMENT ASSOCIATES, INC., et al. /s/ Christian K. Vogel Christian K. Vogel (Va. Bar No. 75537) VOGEL & CROMWELL, LLC 513 Forest Ave., Suite 205 Richmond, Virginia 23229 804.728.1574 [email protected] Vogel & Cromwell, L.L.C. Brian S. Hermann (pro hac vice to be submitted) Alexander Woolverton (pro hac vice to be submitted) PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, New York 10019 Telephone: (212) 373-3000 Facsimile: (212) 757-3990 Email: [email protected] [email protected] Counsel for M.S. Management Associates, Inc. and related Affiliates 3 Case 20-33332-KLP Doc 838 Filed 01/25/21 Entered 01/25/21 21:06:08 Desc Main Document Page 4 of 4 CERTIFICATE OF SERVICE I hereby certify that on the 25th day of January 2021, a true and correct copy of the foregoing Notice of Appearance Pursuant to Bankruptcy Rule 9010 and Request for Notices was served on all persons receiving electronic notice in these cases. /s/ Christian K. Vogel Christian K. Vogel Vogel & Cromwell, L.L.C. 4 .
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