in the united states bankruptcy court for the ......11950144/1 in the united states bankruptcy court...
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11950144/1
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
JUNO USA, LP, et al.,1
Debtors.
Chapter 11
Case No. 19-12484 (MFW)
(Jointly Administered)
Related Docket No. 387
CERTIFICATION OF COUNSEL REGARDING THE SETTLEMENT TRUSTEE’S
FIRST OMNIBUS (SUBSTANTIVE) OBJECTION TO CLAIMS PURSUANT TO
SECTION 502 OF THE BANKRUPTCY CODE,
BANKRUPTCY RULE 3007 AND LOCAL RULE 3007-1
I, Sarah M. Ennis, counsel for the Settlement Trust for Juno USA, LP (“Juno”) and its
affiliated debtors (collectively, the “Debtors”), the reorganized debtors in the above-captioned
cases (the “Chapter 11 Cases”), through Peter Hurwitz, Trustee of the Juno Settlement Trust (the
“Settlement Trustee”), hereby certify as follows:
1. On July 24, 2020, the Settlement Trustee filed the Settlement Trustee’s First
Omnibus (Substantive) Objection to Claims Pursuant to Section 502 of the Bankruptcy Code,
Bankruptcy Rule 3007 and Local Rule 3007-1 [Docket 387] (the “First Omnibus Objection”).
2. Counsel to the Settlement Trustee received informal comments from counsel to
claimant WTC Tower 1 LLC (“WTC”), regarding the Settlement Trustee’s objection to WTC’s
claim, Claim No. 52. The Settlement Trustee and WTC have reached a resolution and intend to
file a stipulation in that regard.
3. The undersigned has reviewed the Court’s docket in this case and no other answer,
objection, or other responsive pleading to the First Omnibus Objection appears thereon.
1 The Debtors in these Chapter 11 Cases, along with the last four digits of each Debtor’s tax identification number,
are: Juno USA, LP (5772); Sabo One LLC (2759); Juno Oregon LLC (4462); Vulcan Cars LLC (4733); GT Forge,
Inc. (1093); and Omaha LLC (8656). The mailing address for the Debtors listed above is 74 West Long Lake Road,
Suite 205, Bloomfield Hills, Michigan 48304.
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11950144/1
Objections to the First Omnibus Objection were required to be filed and served no later than
August 17, 2020, at 4:00 p.m. (prevailing Eastern Time).
4. Attached hereto as Exhibit A is a revised proposed form of order (the “Revised
Order”) removing Claim No. 52 by WTC and otherwise granting the First Omnibus Objection.
Attached as Exhibit B is a blackline of the Revised Order showing the revisions compared to the
Proposed Order that was filed on July 24, 2020.
WHEREFORE, the Settlement Trustee respectfully requests that the Court enter the
Proposed Form of Order attached hereto as Exhibit A at its earliest convenience.
Dated: August 19, 2020
MORRIS JAMES LLP
/s/ Sarah M. Ennis
Eric J. Monzo (DE Bar No. 5214)
Brya M. Keilson (DE Bar No. 4643)
Sarah M. Ennis (DE Bar No. 5745)
500 Delaware Avenue, Suite 1500
Wilmington, DE 19801
Telephone: (302) 888-6800
Facsimile: (302) 571-1750
E-mail: [email protected]
E-mail: [email protected]
E-mail: [email protected]
Counsel to Peter Hurwitz, in his capacity as
Trustee of the Juno Settlement Trust
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EXHIBIT A
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UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE
In re Chapter 11
JUNO USA, LP, et al.,1 Case No. 19-12484 (MFW)
(Jointly Administered)
Debtors. Re: D.I. 387
ORDER SUSTAINING SETTLEMENT TRUSTEE’S FIRST OMNIBUS
(SUBSTANTIVE) OBJECTION TO CLAIMS PURSUANT TO SECTION 502 OF THE
BANKRUPTCY CODE, BANKRUPTCY RULE 3007 AND LOCAL RULE 3007-1
Upon consideration of the Settlement Trustee’s First Omnibus (Substantive) Objection to
Claims Pursuant to Section 502 of the Bankruptcy Code, Bankruptcy Rule 3007 and Local Rule
3007-1 (the “Objection”), by which the Settlement Trust requests the entry of an order pursuant to
Section 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007 and Local Rule 3007-1,
disallowing the No Liability Claims set forth on Exhibit A attached hereto and disallowing the
Equity Claims set forth on Exhibit B attached hereto; and upon consideration of the Hurwitz
Declaration; and it appearing that the Court has jurisdiction over this matter pursuant to 28 U.S.C.
§§ 157 and 1334; and due and adequate notice of the Objection having been given under the
circumstances; and sufficient cause appearing therefor,
IT IS HEREBY ORDERED THAT:
1. The Objection is sustained.
1 The Reorganized Debtors in these Chapter 11 Cases, along with the last four digits of each Debtor’s tax
identification number, are: Juno USA, LP (5772); Sabo One LLC (2759); Juno Oregon LLC (4462); Vulcan Cars LLC
(4733); GT Forge, Inc. (1093); and Omaha LLC (8656). The mailing address for the Debtors listed above is 74 West
Long Lake Road, Suite 205, Bloomfield Hills, Michigan 48304.
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2. The No Liability Claims set forth on the attached Exhibit A under the heading
“Claim No.” are hereby disallowed and expunged in their entirety.
3. The Equity Claims set forth on the attached Exhibit B under the heading “Claim
No.” are hereby disallowed and expunged in their entirety.
4. The rights of the Trust and the Settlement Trustee to: (i) file subsequent objections
to any claims listed on any of the Exhibits hereto on any ground; (ii) amend, modify or supplement
the Objection, including, without limitation, filing objections to further amended or newly-filed
claims; (iii) seek to expunge or reduce any claim to the extent all or a portion of such claim has
been paid; and (iv) settle any claim for less than the asserted amount, are expressly preserved.
Additionally, should one or more of the grounds of objection stated in the Objection be overruled,
the Settlement Trustee’s rights to object to the Disputed Claims on any other grounds are
preserved.
5. The objection to each claim, as addressed in the Objection and as set forth in the
Exhibits, constitutes a separate contested matter as contemplated by Bankruptcy Rule 9014 and
Local Rule 3007-1. This Order shall be deemed a separate order with respect to each such claim
that is the subject of the Objection. Any stay of this Order pending appeal by any claimants whose
claims are subject to this Order shall only apply to the contested matter that involves such claimant
and shall not act to stay the applicability and/or finality of this Order with respect to any other
contested matters addressed in the Objection and this Order.
6. The Settlement Trustee and the Claims Agent are authorized to take any and all
actions that are necessary and appropriate to give effect to this Order.
7. This Court shall retain jurisdiction over all matters arising from or related to the
interpretation and implementation of this Order.
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EXHIBIT A
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NuLnk, Inc., et al. , Case No. 18-11093
Fully Satisfied Claims
NAME CLAIM NO. FILED DATE DEBTOR
ASSERTED CLAIM
CLASS
ASSERTED
CLAIM
AMOUNT ADDRESS
REASON FOR DISALLOWANCE
Evelyn Echevarria C484-26 01/13/2020 Juno USA, LP
Secured
Priority
Unsecured $3,611.00 2075 2nd Ave, Apt 2E New York, NY 10029
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Souleymane Diallo C484-27 01/13/2020 Juno USA, LP
Priority
Unsecured $10,000.00 971 Hegeman Ave, Apt 1 Brooklyn, NY 11208
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Jean-Claude Goundo C484-10 12/31/2019 Juno USA, LP
Unsecured
$0.00 308 Ralph Ave. Apt 3F Brooklyn, NY 11233
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Mostafa Eltalkhawy C484-11 12/31/2019 Juno USA, LP
Unsecured
$3,500.00 6717 Ft Hamilton Pkwy, Apt B2 Brooklyn, NY 11219
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Ramesh Basnef C484-21 01/06/2020 Juno USA, LP
Unsecured
$1,000.00 5155 Van Kleeck St, Apt 2D Elmhurst, NY 11373
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Mamadou T Bah C484-49 01/27/2020 Juno USA, LP
Unsecured
$0.00 1223 Wheeler Ave, Apt 1B Bronx, NY 10472
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Mamadou Moucfar Bah C484-50 01/27/2020 Juno USA, LP
Unsecured
$0.00 1223 Wheeler Ave, Apt 1B Bronx, NY 10472
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
Pooi Ping Lai C484-2515 02/06/2020 Juno USA, LP
Priority
Unsecured $4,819.54 1459 W 8th St Brooklyn, NY 11204
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Ndiaga Ndiaye C484-2521 02/28/2020 Juno USA, LP
Priority
Unsecured $0.00 920 Baychester Ave Bronx, NY 10475
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Giorgi Battinelli C484-2527 06/02/2020 Juno USA, LP Unsecured $30,000.00 217 Quentin Rd Apt 2G Brooklyn NY 11223
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Shi Qin Wu C484-53 01/28/2020 Juno USA, LP Unsecured $2,889.46 Attn: Vicky Zheng 43-40 Union St, Apt 2D Flushing, NY 11355
According to the Debtor's books and records this claim has no basis and
no amount is due and owing to this claimant.
Integrative Neurology, PCC484-15 01/06/2020 Juno USA, LP Unsecured $32,575.00 Attn: Frank W Telang 544 Jefferson Plz., Ste 465 Port Jefferson Station, NY 11776
According to the Debtor's books and records this claim has no basis and
no amount is due and owing to this claimant.
Abubakarr Jolloh C484-35 01/17/2020 Juno USA, LP Unsecured $0.00 1392 Boston Rd, Apt 5C Bronx, NY 10456
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Mohamed Aliou Diallo C484-36 01/17/2020 Juno USA, LP Unsecured $0.00 1429 5th Ave, Apt 36 New York, NY 10035
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Abdraman Mohamed C484-2508 02/01/2020 Juno USA, LP Unsecured $0.00 1917 7th Ave, Apt 3E New York, NY 10026
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Yoro Bass C484-12 01/02/2020 Juno USA, LP Unsecured $0.00 224 W 122nd St, Apt 2C New York, NY 10027
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Constantine Tomaras C484-13 01/02/2020 Juno USA, LP Unsecured $0.00 33-54 28 St, Apt 1C Astoria, NY 11106
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Ivan A Sanchez C484-25 01/13/2020 Juno USA, LP Unsecured $0.00 35-16 88th St Jackson Heights, NY 11372
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Bah Gadiry Abdoul C484-40 01/21/2020 Juno USA, LP Unsecured $0.00 245 E 124 St, Apt 2C New York, NY 10035
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Taopheeq Mustapha C484-41 01/22/2020 Juno USA, LP Unsecured $0.00 216 Rockaway Ave, Apt 8F Brooklyn, NY 11233
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Alpha O Barry C484-42 01/23/2020 Juno USA, LP Unsecured $0.00 1374 Boston Rd, Apt 3A Bronx, NY 10456
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Aminur Rashid C484-48 01/27/2020 Juno USA, LP Unsecured $0.00 14529 123rd Ave Jamaica, NY 111436
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
MD ARIFUL ISLAM C484-2505 01/31/2020 Juno USA, LP Unsecured $5,000.00 165-19 Chapin Pkwy, Apt 3 Jamaica, NY 11432
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Cross River Bank C484-2506 01/31/2020 Juno USA, LP Unsecured $60,000.00 Attn: Jennifer Olivestone 400 Kelby St,14th Fl Fort Lee, NJ 07024
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Momin M Ahmed C484-2511 02/03/2020 Juno USA, LP Unsecured $0.00 6544 162nd St, Ste 2G Flushing, NY 11365
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Ibrahima Sano C484-2512 02/01/2020 Juno USA, LP Unsecured $0.00 91-50 191st St, 6F Hollis, NY 11423
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Djelloul Brakech C484-22 01/09/2020 Juno USA, LP Unsecured $0.00 3042 23rd St, Apt 2H Astoria, NY 11102
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Serge Guerrier C484-28 01/14/2020 Juno USA, LP Unsecured $0.00 1494 E 37th St Brooklyn, NY 11234
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Sherif Elsherbiny C484-29 01/15/2020 Juno USA, LP Unsecured $0.00 40 Manhattan Ave, Apt 2 Jersey City, NJ 07307
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Dajon Davis C484-30 01/15/2020 Juno USA, LP Unsecured $0.00 1600 Sedwick Ave, Apt 9J Bronx, NY 10453
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Maria Tavarez C484-39 01/21/2020 Juno USA, LP Unsecured $10,000.00 353 S 3rd St, Apt 20 Brookyln, NY 11211
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Chuan C Chen C484-2514 02/06/2020 Juno USA, LP
Unsecured
$1,000.00 822 1st St, Apt 2 Brooklyn, NY 11228
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Wilson Y Sanchez C484-2519 02/26/2020 Juno USA, LP
Priority
Unsecured $0.00 45 Fairview Ave, Ste 2I New York, NY 10040
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Zaman Qamar, UL C484-2520 02/10/2020 Juno USA, LP
Unsecured
$15,000.00 Attn: Zaman Qamar 2309 65th St, Unit B4 Brooklyn, NY 11204
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Xianxue Yang C484-9 12/31/2019 Juno USA, LP
Unsecured
$500.00 5946 156th St Brooklyn, NY 11204
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
In re Juno USA, LP, et al. Case No. 19-12484First Omnibus: Exhibit A - No Liability Claims
Page 1 of 1
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EXHIBIT B
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NuLnk, Inc., et al. , Case No. 18-11093
Fully Satisfied Claims
NAME
CLAIM
NO.
FILED
DATE DEBTOR
ASSERTED
CLAIM CLASS
ASSERTED
CLAIM
AMOUNT ADDRESS REASON FOR DISALLOWANCE
Solomon A Obong C484-46 01/24/2020 Juno USA, LP Unsecured $228,750.00 66 Confederation Pl. Staten Island, NY 10303 This claim was filed on account of the Claimant's alleged ownership of an equity interest
in the Debtors based upon events that predate Juno Inc's sale of its Juno brand assets
including its equity interest in Juno USA, LP and Vulcan Cars LLC to GT GETTAXI Limited,
the Debtors parent. The Equity Claim is a claim against non-debtor Juno Inc. for an
alleged equity interest in Juno Inc. and is not a claim for an equity interest in a Debtor.
Given the equity claims are claims against non-debtor Juno Inc. they should be
disallowed and expunged.
In re Juno USA, LP, et al. Case No. 19-12484
First Omnibus: Exhibit B – Equity Claims
Page 1 of 1
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EXHIBIT B
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11955737/1
UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE
In re Chapter 11
JUNO USA, LP, et al.,1 Case No. 19-12484 (MFW)
(Jointly Administered)
Debtors.
ORDER SUSTAINING SETTLEMENT TRUSTEE’S FIRST OMNIBUS
(SUBSTANTIVE) OBJECTION TO CLAIMS PURSUANT TO SECTION 502 OF THE
BANKRUPTCY CODE, BANKRUPTCY RULE 3007 AND LOCAL RULE 3007-1
Upon consideration of the Settlement Trustee’s First Omnibus (Substantive) Objection to
Claims Pursuant to Section 502 of the Bankruptcy Code, Bankruptcy Rule 3007 and Local Rule
3007-1 (the “Objection”), by which the Settlement Trust requests the entry of an order pursuant to
Section 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007 and Local Rule 3007-1,
disallowing the No Liability Claims set forth on Exhibit A attached hereto; and disallowing the
Equity Claims set forth on Exhibit B attached hereto; and modifying the Modified Amount Claims
as set forth on Exhibit C attached hereto; and upon consideration of the Hurwitz Declaration; and
it appearing that the Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334;
and due and adequate notice of the Objection having been given under the circumstances; and
sufficient cause appearing therefor,
IT IS HEREBY ORDERED THAT:
1. The Objection is sustained.
1 The Reorganized Debtors in these Chapter 11 Cases, along with the last four digits of each Debtor’s tax
identification number, are: Juno USA, LP (5772); Sabo One LLC (2759); Juno Oregon LLC (4462); Vulcan Cars LLC
(4733); GT Forge, Inc. (1093); and Omaha LLC (8656). The mailing address for the Debtors listed above is 74 West
Long Lake Road, Suite 205, Bloomfield Hills, Michigan 48304.
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11955737/1
2. The No Liability Claims set forth on the attached Exhibit A under the heading
“Claim No.” are hereby disallowed and expunged in their entirety.
3. The Equity Claims set forth on the attached Exhibit B under the heading “Claim
No.” are hereby disallowed and expunged in their entirety.
4. The Modified Claim Amounts set forth on the attached Exhibit C under the heading
“Claim No.” are hereby modified to the dollar values indicated on the column titled “Modified
Claim Amount” on the attached Exhibit C.
5.4. The rights of the Trust and the Settlement Trustee to: (i) file subsequent objections
to any claims listed on any of the Exhibits hereto on any ground; (ii) amend, modify or supplement
the Objection, including, without limitation, filing objections to further amended or newly-filed
claims; (iii) seek to expunge or reduce any claim to the extent all or a portion of such claim has
been paid; and (iv) settle any claim for less than the asserted amount, are expressly preserved.
Additionally, should one or more of the grounds of objection stated in the Objection be overruled,
the Settlement Trustee’s rights to object to the Disputed Claims on any other grounds are
preserved.
6.5. The objection to each claim, as addressed in the Objection and as set forth in the
Exhibits, constitutes a separate contested matter as contemplated by Bankruptcy Rule 9014 and
Local Rule 3007-1. This Order shall be deemed a separate order with respect to each such claim
that is the subject of the Objection. Any stay of this Order pending appeal by any claimants whose
claims are subject to this Order shall only apply to the contested matter that involves such claimant
and shall not act to stay the applicability and/or finality of this Order with respect to any other
contested matters addressed in the Objection and this Order.
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11955737/1
7.6. The Settlement Trustee and the Claims Agent are authorized to take any and all
actions that are necessary and appropriate to give effect to this Order.
8.7. This Court shall retain jurisdiction over all matters arising from or related to the
interpretation and implementation of this Order.
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EXHIBIT A
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NuLnk, Inc., et al. , Case No. 18-11093
Fully Satisfied Claims
NAME CLAIM NO. FILED DATE DEBTOR
ASSERTED CLAIM
CLASS
ASSERTED
CLAIM
AMOUNT ADDRESS
REASON FOR DISALLOWANCE
Evelyn Echevarria C484-26 01/13/2020 Juno USA, LP
Secured
Priority
Unsecured $3,611.00 2075 2nd Ave, Apt 2E New York, NY 10029
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Souleymane Diallo C484-27 01/13/2020 Juno USA, LP
Priority
Unsecured $10,000.00 971 Hegeman Ave, Apt 1 Brooklyn, NY 11208
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Jean-Claude Goundo C484-10 12/31/2019 Juno USA, LP
Unsecured
$0.00 308 Ralph Ave. Apt 3F Brooklyn, NY 11233
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Mostafa Eltalkhawy C484-11 12/31/2019 Juno USA, LP
Unsecured
$3,500.00 6717 Ft Hamilton Pkwy, Apt B2 Brooklyn, NY 11219
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Ramesh Basnef C484-21 01/06/2020 Juno USA, LP
Unsecured
$1,000.00 5155 Van Kleeck St, Apt 2D Elmhurst, NY 11373
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Mamadou T Bah C484-49 01/27/2020 Juno USA, LP
Unsecured
$0.00 1223 Wheeler Ave, Apt 1B Bronx, NY 10472
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Mamadou Moucfar Bah C484-50 01/27/2020 Juno USA, LP
Unsecured
$0.00 1223 Wheeler Ave, Apt 1B Bronx, NY 10472
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
Pooi Ping Lai C484-2515 02/06/2020 Juno USA, LP
Priority
Unsecured $4,819.54 1459 W 8th St Brooklyn, NY 11204
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Ndiaga Ndiaye C484-2521 02/28/2020 Juno USA, LP
Priority
Unsecured $0.00 920 Baychester Ave Bronx, NY 10475
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Giorgi Battinelli C484-2527 06/02/2020 Juno USA, LP Unsecured $30,000.00 217 Quentin Rd Apt 2G Brooklyn NY 11223
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Shi Qin Wu C484-53 01/28/2020 Juno USA, LP Unsecured $2,889.46 Attn: Vicky Zheng 43-40 Union St, Apt 2D Flushing, NY 11355
According to the Debtor's books and records this claim has no basis and
no amount is due and owing to this claimant.
Integrative Neurology, PCC484-15 01/06/2020 Juno USA, LP Unsecured $32,575.00 Attn: Frank W Telang 544 Jefferson Plz., Ste 465 Port Jefferson Station, NY 11776
According to the Debtor's books and records this claim has no basis and
no amount is due and owing to this claimant.
Abubakarr Jolloh C484-35 01/17/2020 Juno USA, LP Unsecured $0.00 1392 Boston Rd, Apt 5C Bronx, NY 10456
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Mohamed Aliou Diallo C484-36 01/17/2020 Juno USA, LP Unsecured $0.00 1429 5th Ave, Apt 36 New York, NY 10035
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Abdraman Mohamed C484-2508 02/01/2020 Juno USA, LP Unsecured $0.00 1917 7th Ave, Apt 3E New York, NY 10026
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Yoro Bass C484-12 01/02/2020 Juno USA, LP Unsecured $0.00 224 W 122nd St, Apt 2C New York, NY 10027
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Constantine Tomaras C484-13 01/02/2020 Juno USA, LP Unsecured $0.00 33-54 28 St, Apt 1C Astoria, NY 11106
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Ivan A Sanchez C484-25 01/13/2020 Juno USA, LP Unsecured $0.00 35-16 88th St Jackson Heights, NY 11372
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Bah Gadiry Abdoul C484-40 01/21/2020 Juno USA, LP Unsecured $0.00 245 E 124 St, Apt 2C New York, NY 10035
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Taopheeq Mustapha C484-41 01/22/2020 Juno USA, LP Unsecured $0.00 216 Rockaway Ave, Apt 8F Brooklyn, NY 11233
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Alpha O Barry C484-42 01/23/2020 Juno USA, LP Unsecured $0.00 1374 Boston Rd, Apt 3A Bronx, NY 10456
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Aminur Rashid C484-48 01/27/2020 Juno USA, LP Unsecured $0.00 14529 123rd Ave Jamaica, NY 111436
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
MD ARIFUL ISLAM C484-2505 01/31/2020 Juno USA, LP Unsecured $5,000.00 165-19 Chapin Pkwy, Apt 3 Jamaica, NY 11432
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Cross River Bank C484-2506 01/31/2020 Juno USA, LP Unsecured $60,000.00 Attn: Jennifer Olivestone 400 Kelby St,14th Fl Fort Lee, NJ 07024
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Momin M Ahmed C484-2511 02/03/2020 Juno USA, LP Unsecured $0.00 6544 162nd St, Ste 2G Flushing, NY 11365
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Ibrahima Sano C484-2512 02/01/2020 Juno USA, LP Unsecured $0.00 91-50 191st St, 6F Hollis, NY 11423
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Djelloul Brakech C484-22 01/09/2020 Juno USA, LP Unsecured $0.00 3042 23rd St, Apt 2H Astoria, NY 11102
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Serge Guerrier C484-28 01/14/2020 Juno USA, LP Unsecured $0.00 1494 E 37th St Brooklyn, NY 11234
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Sherif Elsherbiny C484-29 01/15/2020 Juno USA, LP Unsecured $0.00 40 Manhattan Ave, Apt 2 Jersey City, NJ 07307
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Dajon Davis C484-30 01/15/2020 Juno USA, LP Unsecured $0.00 1600 Sedwick Ave, Apt 9J Bronx, NY 10453
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Maria Tavarez C484-39 01/21/2020 Juno USA, LP Unsecured $10,000.00 353 S 3rd St, Apt 20 Brookyln, NY 11211
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Chuan C Chen C484-2514 02/06/2020 Juno USA, LP
Unsecured
$1,000.00 822 1st St, Apt 2 Brooklyn, NY 11228
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Wilson Y Sanchez C484-2519 02/26/2020 Juno USA, LP
Priority
Unsecured $0.00 45 Fairview Ave, Ste 2I New York, NY 10040
No liability has been asserted and even if a liablity had been asserted the
Debtors books and records indicate this claimant has been paid in full all
amounts due and owing.
Zaman Qamar, UL C484-2520 02/10/2020 Juno USA, LP
Unsecured
$15,000.00 Attn: Zaman Qamar 2309 65th St, Unit B4 Brooklyn, NY 11204
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
Xianxue Yang C484-9 12/31/2019 Juno USA, LP
Unsecured
$500.00 5946 156th St Brooklyn, NY 11204
According to the Debtor's books and records this claim has no basis and
all amounts due and owing have been fully paid to this claimant.
In re Juno USA, LP, et al. Case No. 19-12484First Omnibus: Exhibit A - No Liability Claims
Page 1 of 1
Case 19-12484-MFW Doc 387-3 Filed 07/24/20 Page 2 of 6Case 19-12484-MFW Doc 390-2 Filed 08/19/20 Page 6 of 10
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EXHIBIT B
Case 19-12484-MFW Doc 390-2 Filed 08/19/20 Page 7 of 10
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NuLnk, Inc., et al. , Case No. 18-11093
Fully Satisfied Claims
NAME
CLAIM
NO.
FILED
DATE DEBTOR
ASSERTED
CLAIM CLASS
ASSERTED
CLAIM
AMOUNT ADDRESS REASON FOR DISALLOWANCE
Solomon A Obong C484-46 01/24/2020 Juno USA, LP Unsecured $228,750.00 66 Confederation Pl. Staten Island, NY 10303 This claim was filed on account of the Claimant's alleged ownership of an equity interest
in the Debtors based upon events that predate Juno Inc's sale of its Juno brand assets
including its equity interest in Juno USA, LP and Vulcan Cars LLC to GT GETTAXI Limited,
the Debtors parent. The Equity Claim is a claim against non-debtor Juno Inc. for an
alleged equity interest in Juno Inc. and is not a claim for an equity interest in a Debtor.
Given the equity claims are claims against non-debtor Juno Inc. they should be
disallowed and expunged.
In re Juno USA, LP, et al. Case No. 19-12484
First Omnibus: Exhibit B – Equity Claims
Page 1 of 1
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EXHIBIT C
Case 19-12484-MFW Doc 390-2 Filed 08/19/20 Page 9 of 10
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11955815/1
In re Juno USA, LP, et al. Case No. 19-12484
First Omnibus: Exhibit C – Modified Amount Claims
CLAIM NO. DEBTOR ASSERTED
CLAIM CLASS
ASSERTED
CLAIM
AMOUNT
MODIFIED
CLAIM CLASS
MODIFIFED
CLAIM
AMOUNT
REASON FOR
MODIFICATION
WTC Tower 1
LLC
c/o Royal 1
WTC
Management,
LLC
Attn: Jonathan
Durst
One Bryant Park
New York, NY
10017
52 Juno USA, LP
(Case No. 19-
12484)
Secured
Administrative
Priority
Unsecured
Subtotal
$0.00
$0.00
$606,566.31
$606,566.31
Secured
Administrative
Priority
Unsecured
Subtotal
$0.00
$0.00
$535,208.02
$535,208.02
The proof of claim
asserts liability for at
least $606,566.31 for
damages allegedly
caused by the
Debtors' rejection of
the claimant's real
property lease. The
Settlement Trustee
has reviewed the
claim and has applied
the Statutory
Damages Cap, which
only allows for a
claim of $535,208.02
to account for 12
months of base rent
rather than the 13
months asserted in
the proof of claim.
Accordingly, the
proof of claim should
be modified to reflect
this statutorily
proscribed amount.
Case 19-12484-MFW Doc 390-2 Filed 08/19/20 Page 10 of 10