IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

Chapter
MERVYN'S HOLDING, LLC, et al.,

LL

cAsE NO. 08- 11s86 (KG)

RESPONSE OF HANNELORE KRAMER TO DEBTOR'S OBIECTION TO CERTATN OVERSTATED CLAIMS AND MOTION TO REDUCE OR EXPUNGE SUCH

CLAIMS
Name of Responding Party and Nature of Claim 1.) The respondingParry and claimant is Hannelore Kramer, assigned claim number 6409 onDebtor's Exhibit

"A"

ofoverstated claims. Claimant was injured in

Debtor's Marysville California store on May 30,2008. Claimant was struck by a shopping cart pushed by two minor children in Debtor's store. The minor's were unsupervised and were permitted by Mervyn employees to push the shopping carts through the clothes rack, thereby causing serious bodily injury to Claiman! who was
serval months post hip replacement surgery. Responding party suffered through two more surgeries as a result of the injuries suffered in the Mervyn's store. Responding

party's medical expenses were in excess of $200,000.00.

0q/v)+$ !~ 0811586091104000000000001

Grounds for Obiection to Requested Reliqf 2.) Responding parties claim is unliquidated. For Debtor's declarant to claim the
claim is "overstated" is unsupported by any evidence. Nothirg ir, David Robson's declaration addresses the merits of the responding parties personal injury claim.
Robson's declaration is nothing more than a wholesale denial of claims without any

supporting evidence upon which the court could rely to determine whether the claim
has merit or is in fact overstated. A claim cannot be overstated, if the amount has never been stated.

3.) Debtor's objection is simply another attempt to have the court disallow
legitimate claim of a person who was serious injured at the hands of the debtor.

4.) For the reasons stated, the objection and motion should be denied respondingparry.

as

to

8.) The name, address and telephone number of the person to whom

reply to

this response should be directed, and who has ultimate authority to reconcile, settle or otherwise resolve this claim on behalf of claimant is set forth below. Dated: November

3, 2009
By: Attorney Al f. Carrion 1528 Starr Drive, Suite B Yuba City, California 95993 Telephone: (530) 674-4500 Facsimile : (530) 67 4-4549 Email: Carrion@vclaw.com