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. Case 19-12484-MFW Doc 390 Filed 08/19/20 Page 1 of 2

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Page 1: IN THE UNITED STATES BANKRUPTCY COURT FOR THE ......11950144/1 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: JUNO USA, LP, et al.,1 Debtors. Chapter 11

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.

Case 19-12484-MFW Doc 390 Filed 08/19/20 Page 1 of 2

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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

Case 19-12484-MFW Doc 390 Filed 08/19/20 Page 2 of 2

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EXHIBIT A

Case 19-12484-MFW Doc 390-1 Filed 08/19/20 Page 1 of 7

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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.

Case 19-12484-MFW Doc 390-1 Filed 08/19/20 Page 2 of 7

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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.

Case 19-12484-MFW Doc 390-1 Filed 08/19/20 Page 3 of 7

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EXHIBIT A

Case 19-12484-MFW Doc 390-1 Filed 08/19/20 Page 4 of 7

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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 390-1 Filed 08/19/20 Page 5 of 7

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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

Case 19-12484-MFW Doc 387-3 Filed 07/24/20 Page 4 of 6Case 19-12484-MFW Doc 390-1 Filed 08/19/20 Page 7 of 7

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EXHIBIT B

Case 19-12484-MFW Doc 390-2 Filed 08/19/20 Page 1 of 10

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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.

Case 19-12484-MFW Doc 390-2 Filed 08/19/20 Page 2 of 10

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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.

Case 19-12484-MFW Doc 390-2 Filed 08/19/20 Page 3 of 10

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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.

Case 19-12484-MFW Doc 390-2 Filed 08/19/20 Page 4 of 10

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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

Case 19-12484-MFW Doc 387-3 Filed 07/24/20 Page 4 of 6Case 19-12484-MFW Doc 390-2 Filed 08/19/20 Page 8 of 10

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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