Hearing Date:July 14, 2011 at 10:00 a.m. (Prevailing Eastern Time)Objection Deadline (for Committee): July 13, 2011 at 12:00 noon (Prevailing Eastern Time)
Bruce S. Nathan, Esq.Bruce Buechler, Esq.PaulKizel, Esq.
LOWENSTEIN SANDLER PC
1251 Avenue of the AmericasNew York, New York 10020Tel: (212) 262-6700Fax: (212) 262-7402--and --65 Livingston AvenueRoseland, NJ 07068Tel: (973) 597-2500Fax: (973) 597-2400
Counsel to the Official Committeeof Unsecured Creditors
UNITED STATES BANKRUPTCY COURTSOUTHERN DISTRICT OF NEW YORKIn re:BORDERS GROUP, INC.,
Debtors.Chapter 11Case No. 11-10614 (MG)Jointly AdministeredOBJECTIONOF THE OFFICIAL COMMITTEE OF UNSECUREDCREDITORSTOBID PROCEDURES AND BREAK-UP FEE CONTAINED INTHE DEBTORS’ MOTIONFOR AN ORDER PURSUANT TO SECTIONS 105, 363 AND 365 OF THEBANKRUPTCY CODE AND RULES 2002, 6004, 6006 AND 9014 OF THE FEDERALRULES OF BANKRUPTCY PROCEDURE (I) APPROVING THE SALE OFSUBSTANTIALLY ALL OFTHE DEBTORS’ ASSETSFREE AND CLEAR OF ALLLIENS, CLAIMS, ENCUMBRANCES AND INTERESTS AND THE ASSUMPTIONANDASSIGNMENT OF EXECUTORY CONTRACTS AND UNEXPIRED LEASESRELATED THERETO, (II) APPROVING THE SALE PROCEDURES ANDBREAK-UP FEE, AND (III) GRANTING RELATED RELIEF
The Official Committee of Unsecured Creditors (the “Committee”) of BordersGroup, Inc.,
., the above-captioned debtors and debtors-in-possession (collectively, the“Debtors”), byand through its undersigned counsel, submits this objection (the “Objection”) to
The Debtors in these cases, along with the last four digits of each Debtor’s federal taxidentification number, are: Borders Group, Inc. (4588); Borders International Services, Inc.(5075); Borders, Inc. (4285); Borders Direct, LLC (0084); Borders Properties, Inc. (7978);Borders Online, Inc. (8425); Borders Online, LLC (8996); and BGP (UK) Limited.