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Full title: Motion to Extend Reorganized Debtors' Motion for an Order Extending the Claims Objection Bar Date Filed by AAC Holdings, Inc.. Hearing scheduled for 6/30/2021 at 10:00 AM at US Bankruptcy Court, 824 Market St., 3rd Fl., Courtroom #7, Wilmington, Delaware. Objections due by 6/17/2021. (Attachments: # 1 Exhibit A - Proposed Order # 2 Notice) (Meloro, Dennis) (Entered: 06/03/2021)

Document posted on Jun 2, 2021 in the bankruptcy, 7 pages and 0 tables.

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The above-captioned reorganized debtors (collectively, the “Reorganized Debtors”)2 respectfully request the Court enter an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), extending the deadline by which the Reorganized Debtors or the Litigation Trustee, as applicable, may object to Claims (the “Claims Objection Bar Date”) 1 The Reorganized Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are: Recovery First of Florida, LLC (3005);Fitrx, LLC (5410); Oxford Treatment Center, LLC (7853); Oxford Outpatient Center, LLC (0237); Concorde Treatment Center, LLC (6483); New Jersey Addiction Treatment Center, LLC (7108); ABTTC, LLC (7601); Laguna Treatment Hospital, LLC (0830); AAC Las Vegas Outpatient Center, LLC (5381); Greenhouse Treatment Center, LLC (4402); AAC Dallas Outpatient Center, LLC (6827); Forterus Health Care Services, Inc. (4758); Solutions Treatment Center, LLC (8175); San Diego Addiction Treatment Center, Inc. (1719); River Oaks Treatment Center, LLC (0640); Singer Island Recovery Center LLC (3015); B&B Holdings Intl LLC (8549); The Academy Real Estate, LLC (9789); BHR Oxford Real Estate, LLC (0023); Concorde Real Estate, LLC (4295); BHR Ringwood Real Estate, LLC (0565); BHR Aliso Viejo Real Estate, LLC (2910); Behavioral Healthcare Realty, LLC (2055); Clinical Revenue Management Services, LLC (8103); Recovery Brands, LLC (8920); Referral Solutions Group, LLC (7817); Taj Media LLC (7047); Sober Media Group, LLC (4655); American Addiction Centers, Inc. (3320); Tower Hill Realty, Inc. (0039); Lincoln Catharine Realty Corporation (5998); AdCare Rhode Island, Inc. (2188); Green Hill Realty Corporation (4951); AdCare Hospital of Worcester, Inc. (3042); Diversified Healthcare Strategies, Inc. (3809); AdCare Criminal Justice Services, Inc. (1653); AdCare, Inc. (7005); Sagenex Diagnostics Laboratory, LLC (7900); RI - Clinical Services, LLC (6291); Addiction Labs of America, LLC (1133); AAC Healthcare Network, Inc. (0677); AAC Holdings, Inc. (6142); San Diego Professional Group, P.C. (9334).Additionally, under the Bar Date Order, holders of claims against the Debtors arising from the rejection by the Debtors of an executory contract or unexpired lease must file a proof of claim on or before the later of (a) the General Bar Date, (b) 30 days after service of an order by the Court authorizing such rejection, or (c) such other date, if any, as the Court may fix in the order authorizing such rejection.The Plan further provides that the deadline for objecting to Claims, including Administrative Claims, is the later of (a) 180 days after the Effective Date and (b) such other period of limitation as may be specifically fixed by order of the Bankruptcy Court for objecting to Claims.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 AAC HOLDINGS, INC., et al.,1 Case No. 20-11648 (CTG) Reorganized Debtors. (Jointly Administered) Objection Deadline: June 17, 2021 at 4:00 p.m. (ET) Hearing Date: June 30, 2021 at 10:00 a.m. (ET) REORGANIZED DEBTORS’ MOTION FOR AN ORDER EXTENDING THE CLAIMS OBJECTION BAR DATE The above-captioned reorganized debtors (collectively, the “Reorganized Debtors”)2 respectfully request the Court enter an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), extending the deadline by which the Reorganized Debtors or the Litigation Trustee, as applicable, may object to Claims (the “Claims Objection Bar Date”) 1 The Reorganized Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are: Recovery First of Florida, LLC (3005); Fitrx, LLC (5410); Oxford Treatment Center, LLC (7853); Oxford Outpatient Center, LLC (0237); Concorde Treatment Center, LLC (6483); New Jersey Addiction Treatment Center, LLC (7108); ABTTC, LLC (7601); Laguna Treatment Hospital, LLC (0830); AAC Las Vegas Outpatient Center, LLC (5381); Greenhouse Treatment Center, LLC (4402); AAC Dallas Outpatient Center, LLC (6827); Forterus Health Care Services, Inc. (4758); Solutions Treatment Center, LLC (8175); San Diego Addiction Treatment Center, Inc. (1719); River Oaks Treatment Center, LLC (0640); Singer Island Recovery Center LLC (3015); B&B Holdings Intl LLC (8549); The Academy Real Estate, LLC (9789); BHR Oxford Real Estate, LLC (0023); Concorde Real Estate, LLC (7890); BHR Greenhouse Real Estate, LLC (4295); BHR Ringwood Real Estate, LLC (0565); BHR Aliso Viejo Real Estate, LLC (2910); Behavioral Healthcare Realty, LLC (2055); Clinical Revenue Management Services, LLC (8103); Recovery Brands, LLC (8920); Referral Solutions Group, LLC (7817); Taj Media LLC (7047); Sober Media Group, LLC (4655); American Addiction Centers, Inc. (3320); Tower Hill Realty, Inc. (0039); Lincoln Catharine Realty Corporation (5998); AdCare Rhode Island, Inc. (2188); Green Hill Realty Corporation (4951); AdCare Hospital of Worcester, Inc. (3042); Diversified Healthcare Strategies, Inc. (3809); AdCare Criminal Justice Services, Inc. (1653); AdCare, Inc. (7005); Sagenex Diagnostics Laboratory, LLC (7900); RI - Clinical Services, LLC (6291); Addiction Labs of America, LLC (1133); AAC Healthcare Network, Inc. (0677); AAC Holdings, Inc. (6142); San Diego Professional Group, P.C. (9334). Grand Prairie Professional Group, P.A. (2102); Palm Beach Professional Group, Professional Corporation (7608); Pontchartrain Medical Group, A Professional Corporation (1271); Oxford Professional Group, P.C. (8234); and Las Vegas Professional Group - Calarco, P.C. (5901). The location of the Reorganized Debtors’ corporate headquarters is 200 Powell Place, Brentwood, TN 37027. 2 Prior to the occurrence of the Effective Date (as defined, infra), the Reorganized Debtors were debtors and debtors in possession (collectively, the “Debtors”) in these chapter 11 cases (the “Chapter 11 Cases”).

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through and including December 1, 2021, and in support thereof, respectfully represent as follows: JURISDICTION 1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Amended Standing Order of Reference from the United States District Court for the District of Delaware, dated February 29, 2012. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Under 9013-1(f) of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware, the Reorganized Debtors consent to entry of a final order under Article III of the United States Constitution. Venue is proper in this district pursuant to 28 U.S.C. §§ 1408 and 1409. BACKGROUND A. General Background 2. On June 20, 2020, each of the Debtors filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code in this Court. 3. On October 20, 2020, the Court entered an order [Docket No. 695] (the “Confirmation Order”) confirming the Second Amended Joint Chapter 11 Plan of AAC Holdings, Inc. and Its Debtor Affiliates [Docket No. 647] (the “Plan”).3 The Effective Date occurred on December 11, 2020 [Docket No. 807]. 4. The Plan provides for the establishment of the Litigation Trust, for the benefit of certain unsecured creditors, to hold certain assets and make distributions to the Debtors’ unsecured creditors on account of Class 4 Junior Lender Secured Claims and Class 5 General 3 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the Plan.

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Unsecured Claims. See generally Plan, Art. III(B)(4), (5) and Art. VII. The Plan further provides that the Litigation Trust shall be administered by the Litigation Trustee.4 B. Claims Bar Date 5. On July 23, 2020, the Court entered its Order (I) Fixing Deadline for Filing Proofs of Claim and (II) Approving the Form and Manner of Notice Thereof [Docket No. 189] (the “Bar Date Order”). 6. Pursuant to the Bar Date Order, August 26, 2020 (the “General Bar Date”) was established as the deadline for all entities or persons, except any governmental unit, to file proofs of claim, including under section 503(b)(9) of the Bankruptcy Code, and December 17, 2020, was established as a deadline for all governmental units to file proofs of claim. Additionally, under the Bar Date Order, holders of claims against the Debtors arising from the rejection by the Debtors of an executory contract or unexpired lease must file a proof of claim on or before the later of (a) the General Bar Date, (b) 30 days after service of an order by the Court authorizing such rejection, or (c) such other date, if any, as the Court may fix in the order authorizing such rejection. 7. As of the date of this Motion, 1,359 claims have been filed against the Debtors’ estates, including more than 200 claims that assert a secured, administrative, or priority Claim. C. Claims Resolution Process and Claims Objection Bar Date 8. Article IX.B of the Plan provides that (a) the Reorganized Debtors shall have the sole authority to file and prosecute objections to Claims, other than General Unsecured Claims, and (b) the Litigation Trustee shall have the sole authority to file and prosecute objections to General Unsecured Claims. 4 Peter Kravitz was appointed as the Litigation Trustee pursuant to the terms and conditions of the Litigation Trust Agreement.

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9. The Plan further provides that the deadline for objecting to Claims, including Administrative Claims, is the later of (a) 180 days after the Effective Date and (b) such other period of limitation as may be specifically fixed by order of the Bankruptcy Court for objecting to Claims. See Plan, Art. I(A)(18) (defining “Claims Objection Bar Date”); Art. II(A) (providing that objections to requests for payment of Administrative Claims must be filed by the Claims Objection Bar Date); Art. IX(E) (providing that objections to Claims shall be filed on or before the Claims Objection Bar Date). Accordingly, the initial Claims Objection Bar Date under the Plan is June 9, 2021. 10. The Reorganized Debtors, the Litigation Trustee, and their respective advisors are reviewing, analyzing, and reconciling claims on an ongoing basis as part of the claims reconciliation process that includes identifying categories of claims that may be targeted for disallowance and expungement, reduction and allowance, or reclassification. As part of this ongoing process, the Reorganized Debtors and the Litigation Trustee are comparing the filed proofs of claim and requests for payment of administrative expenses with the Reorganized Debtors’ books and records to determine the validity of the asserted claims. 11. As of the date of this motion, however, the Reorganized Debtors and Litigation Trustee have not completed their review. In accordance with Article IX(E) of the Plan, the Reorganized Debtors seek an order of this Court extending the Claims Objection Bar Date by approximately six months through and including December 1, 2021. No prior extensions of the Claims Objection Bar Date have been requested or granted in these Chapter 11 Cases. RELIEF REQUESTED 12. The Reorganized Debtors request that the Court enter the Proposed Order extending the Claims Objection Bar Date through and including December 1, 2021, without

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prejudice to the rights of the Reorganized Debtors, the Litigation Trustee, or any successor-in-interest to seek further extensions thereof. BASIS FOR RELIEF 13. An extension of the Claims Objection Bar Date is warranted here to ensure that all claims that warrant objections are identified and objected to so that all creditors receive just and equitable distributions under the terms of the Plan. Bankruptcy Rule 9006(b)(1) governs a request for extension of time to object to claims and provides, in relevant part: [W]hen an act is required or allowed to be done at or within a specified period . . . by order of court, the court for cause shown may at any time in its discretion . . . order the period enlarged if the request therefore is made before expiration of the period originally prescribed or as extended by a previous order . . . . Fed. R. Bankr. P. 9006(b)(1). To determine whether “cause” exists to extend the deadline to object to claims, courts have considered such factors as the size and complexity of the issues involved, the debtor’s good faith progress in resolving issues, the amount of time elapsed in the case, and whether any prejudice will result to the creditors. In re Express One Int’l, Inc., 194 B.R. 98, 100 (Bankr. E.D. Tex. 1996). 14. The Reorganized Debtors submit that cause exists to extend the Claims Objection Bar Date here. More than 1,350 Claims have been filed against the Debtors’ estates, of which more than 200 assert secured, administrative, or other priority claims. While the Litigation Trustee has sole responsibility for administering General Unsecured Claims, the Reorganized Debtors have sole responsibility for administering all other Claims. The Reorganized Debtors are continuing to review and analyze all such claims to determine whether they have been satisfied in accordance with the terms of the Plan and whether there are appropriate grounds for the Reorganized Debtors to object to any such claims. Although the Reorganized Debtors have made progress in reviewing such Claims, the review is ongoing, and the Reorganized Debtors will

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need additional time to object to or seek consensual resolution with the holders of any such claims. Likewise, the Litigation Trustee is still in the process of reviewing the General Unsecured Claims asserted against the Debtors’ estates to determine whether there are appropriate grounds to object to such claims and needs additional time to complete his review. Accordingly, an extension of the Claims Objection Bar Date as requested herein is appropriate and warranted under the circumstances. NOTICE 15. Notice of this Motion has been or will be provided to (i) the Office of the United States Trustee for the District of Delaware; (ii) counsel to the ad hoc committee of certain Senior Lenders and Junior Lenders and the Initial DIP Lenders; (iii) counsel to the Prepetition Agents; (iv) counsel to the Litigation Trustee; and (v) any party who has requested notice in these Chapter 11 Cases pursuant to Rule 2002 of the Federal Rules of Bankruptcy Procedure. The Reorganized Debtors respectfully submit that no further notice of this Motion is required. NO PRIOR REQUEST 16. No prior motion for the relief requested herein has been made to this or any other court.

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CONCLUSION WHEREFORE the Reorganized Debtors respectfully request that the Court enter the Proposed Order extending the Claims Objection Bar Date, and grant such other and further relief as the Court deems appropriate. Dated: June 3, 2021 Respectfully submitted, Wilmington, Delaware GREENBERG TRAURIG, LLP /s/ Dennis A. Meloro Dennis A. Meloro (DE Bar No. 4435) The Nemours Building 1007 North Orange Street, Suite 1200 Wilmington, Delaware 19801 Telephone: (302) 661-7000 Facsimile: (302) 661-7360 Email: melorod@gtlaw.com - and - David B. Kurzweil (admitted pro hac vice) Alison Elko Franklin (admitted pro hac vice) Terminus 200 3333 Piedmont Road, NE, Suite 2500 Atlanta, Georgia 30305 Telephone: (678) 553-2100 Facsimile: (678) 553-2212 Email: kurzweild@gtlaw.com franklinae@gtlaw.com Counsel for the Reorganized Debtors

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