Case GLT Doc 747 Filed 07/20/17 Entered 07/20/17 14:44:10 Desc Main Document Page 1 of 6

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1 Document Page 1 of 6 UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF PENNSYLVANIA In re: ) ) rue21, inc., et al. ) Case No (GLT) ) Chapter 11 ) Debtors. ) (Jointly Administered) ) VERIFIED STATEMENT OF CLARK HILL PLC PURSUANT TO RULE 2019 OF FEDERAL RULES OF BANKRUPTCY PROCEDURE Clark Hill PLC ( Clark Hill ) submits this verified statement pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure, and respectfully states as follows: 1. For purposes of this Statement, the address of Clark Hill is 151 S. Old Woodward Ave., Ste. 200, Birmingham, MI Subject to continued investigation, and reserving all rights, Clark Hill believes that it does not hold prepetition unsecured claims against the Debtors. 2. Clark Hill currently represents the following entities (the Clients ) as creditors and/or parties-in-interest with respect to the above-captioned bankruptcy case (the Case ): SFP Pool One Shopping Centers L.P. and SFP Pool Seven, LLC c/o Warren Strietzel Schostak Brothers & Company, Inc Laurel Park Drive N., Ste. 200 C Livonia MI Mt. Pleasant Shopping Center, LLC c/o Laith Hermiz Agree Realty Corporation 70 E. Long Lake Road, Bloomfield Hills, MI Vestar LPTC, LLC, Vestar QCM, L.L.C., Coventry III/Satterfield Helm Valley Fair, LLC Merle Hay Investors, LLC c/o Norris Eber 30 N. LaSalle Street Suite 2120 Chicago, IL Covington Gateway Acquisition 1-25, LLC, Capital Mall JC 1, LLC, Pine Ridge Mall JC c/o Kylie Kakenmaster Covington Realty Partners 30 S. Wacker Drive, Suite 2750 Chicago, IL Janaf Shopping Center, LLC c/o Maggie Spillane McKinley, Inc /316886

2 Document Page 2 of 6 c/o R. Patrick McGinley Vestar 2425 East Camelback Road, Ste. 750 Phoenix, AZ Green Oak Phase II Owner, LLC c/o Sean Valentino REDICO One Towne Square #1600 Southfield MI Vestar LPTC, LLC, Vestar QCM, L.L.C., Coventry III/Satterfield Helm Valley Fair, LLC c/o R. Patrick McGinley Vestar 2425 East Camelback Road, Ste. 750 Phoenix, AZ E. Virginia Beach Blvd., Suite 520 Norfolk, VA Welling W. Fruehauf 389 Mallory Ct. Naples, FL KIR Snellville L.P., Primrose Marketplace 625, LLC, Temple Towne Center, L.P., Kimco Mesa, LLC, Kimco Lake Prairie TC, L.P., Copperwood Village LP, PK I Gresham Town Fair LLC, RB Quakertown, LP c/o Susan Masone Kimco Realty Corporation 3333 New Hyde Park Rd., Suite 100 New Hyde Park NY Blue Springs Development Three, Inc. RED Lee s Summit East, LLC Sparks Legends Development, Inc. PK I Sunset Esplanade LLC 3. Clark Hill has represented each of the Clients with respect to various matters prior to the date of commencement of the Case. 4. The Clients currently hold unsecured pre-petition claims, unsecured rejection claims and/or post-petition administrative claims for unpaid rent and other charges. The full amount of each of the Clients claims is undetermined at this time /

3 Document Page 3 of 6 5. The Clients have all retained Clark Hill to represent them with respect to their interests in connection with the above captioned case. All parties are being billed on a monthly basis. All parties are aware of Clark Hill s representation of other clients in this matter. 6. All of the Clients have waived the conflict of interests that might exist between them. 7. Upon information and belief formed after due inquiry, Clark Hill does not own any claims against, or equity interests in, the Debtor. 8. Clark Hill has no written contracts of representation with the Clients other than ordinary and usual engagement letters. 9. Clark Hill represents each Client individually and they do not constitute a committee. 10. If Clark Hill undertakes an additional representation of other clients in this Chapter 11 Case, this statement will be supplemented in accordance with Bankruptcy Rule Neither this Statement, nor any previous or subsequent appearance, pleading, claim or suit, is intended to waive: (a) any Client s right to have final orders in non-core matters entered only after de novo review by a federal district court judge; (b) any Client s right to trial by jury in any proceeding so triable herein or in any case, controversy or proceeding related hereto; (c) any Client s right to have the reference withdrawn by the federal district court in any matter subject to mandatory or discretional withdrawal; (d) any Client s right to object to the subject-matter jurisdiction of the Court and shall not be deemed or construed as a submission of any Client to the jurisdiction of the Court; and (e) any other rights, claims, actions, defenses, setoffs, or recoupments to which any Client is or may be entitled in law or in equity, all of which rights, claims, actions, defenses, setoffs, and recoupments are expressly reserved by each Client /

4 Document Page 4 of 6 Verification I hereby certify that, based on inquiry, the foregoing facts and statements are true and correct, to the best of my knowledge, information, and belief. Clark Hill reserves the right to revise and supplement this statement /

5 Document Page 5 of 6 Respectfully submitted, CLARK HILL PLC Date: July 20, 2017 By: /s/ David M. Blau David M. Blau Esq. (Admitted pro hac vice) Michigan Bar No. P S. Old Woodard Ave., Ste. 200 Birmingham, MI Telephone: (248) Fax: (248) dblau@clarkhill.com AND By: /s/william C. Price William C. Price (PA ID No ) One Oxford Centre 301 Grant Street, 14th Floor Pittsburgh, PA Phone: Fax: wprice@clarkhill.com Attorneys for Janaf Shopping Center, LLC, Mt. Pleasant Shopping Center, LLC, Covington Gateway Acquisition 1-25, LLC, Adrian Acquisition, LLC, Vestar LPTC, LLC, Vestar QCM, L.L.C., Coventry III/Satterfield Helm Valley Fair, LLC, Merle Hay Investors, LLC, Green Oak Phase II Owner, LLC, Welling W. Fruehauf, KIR Snellville L.P., Primrose Marketplace 625, LLC, Temple Towne Center, L.P., Kimco Mesa, LLC, Kimco Lake Prairie TC, L.P., Copperwood Village LP, PK I Gresham Town Fair LLC, RB Quakertown, LP, Capital Mall JC 1, LLC, Pine Ridge Mall JC, LLC, SFP Pool One Shopping Centers L.P.,SFP Pool Seven, LLC, Blue Springs Development Three, Inc., Sparks Legends Development, Inc., RED Lee s Summit East, LLC, and PK I Sunset Esplanade, LLC /

6 Document Page 6 of 6 CERTIFICATE OF SERVICE I hereby certify that on July 20, 2017, a true and correct copy of the foregoing was filed with the Clerk of the Court and served on all parties receiving notices in this case through the Court s CM/ECF system. By:/s/ William C. Price William C. Price /316886