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Full title: Omnibus Objection to Claims (Debtors' Second Omnibus Objection (Non-Substantive) With Respect to (I) Certain Duplicate Claims and (II) Certain Amended Claims). Filed by EHT US1, Inc.. Hearing scheduled for 9/24/2021 at 11:00 AM at US Bankruptcy Court, 824 Market St., 5th Fl., Courtroom #6, Wilmington, Delaware. Objections due by 9/17/2021. (Attachments: # 1 Notice of Objection # 2 Exhibit A - Proposed Order # 3 Exhibit B - Foster Declaration) (Dean, G.) (Entered: 08/06/2021)

Document posted on Aug 5, 2021 in the bankruptcy, 12 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

1 The Debtors in these chapter 11 cases, along with the last four digits of each debtor’s tax identification number, as applicable, are as follows: EHT US1, Inc.(6703); 5151 Wiley Post Way, Salt Lake City, LLC (1455); ASAP Cayman Atlanta Hotel LLC (2088); ASAP Cayman Denver Tech LLC (7531); ASAP Cayman Salt Lake City Hotel LLC (7546); ASAP Salt Lake City Hotel, LLC (7146); Atlanta Hotel Holdings, LLC (6450); CI Hospitality Investment, LLC (7641); Eagle Hospitality Real Estate Investment Trust (7734); Eagle Hospitality Trust S1 Pte.UCCONT1, LLC (0463); UCF 1, LLC (6406); UCRDH, LLC (2279); UCHIDH, LLC (6497); Urban Commons 4th Street A, LLC (1768); Urban Commons Anaheim HI, LLC (9915); Urban Commons Bayshore A, LLC (2422); Urban Commons Cordova A, LLC (4152); Urban Commons Danbury A, LLC (4388); Urban Commons Highway 111 A, LLC (4497); Urban Commons Queensway, LLC (6882); Urban Commons Riverside Blvd., A, LLC (4661); and USHIL Holdco Member, LLC (4796).By this Objection, the Debtors seek entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”) disallowing and expunging each of the Duplicate Claims (as defined herein) and Amended Claims (as defined herein) identified on Exhibit 1 and Exhibit 2 attached to the Proposed Order, respectively. The Debtors, with the assistance of their advisors, have actively begun reviewing and reconciling proofs of claim with the Debtors’ Schedules and Books and Records, which process includes identifying certain categories of claims that may be subject to objection and/or reclassification.Each claim set forth on Exhibit 1to the Proposed Order under the column titled “Duplicate Claim to be Disallowed” (the “Duplicate Claims”) are duplicative of a proof of claim listed under the column titled “Remaining Claim Number” on Exhibit 1 (the “Remaining Claims”).

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ------------------------------------------------------------- x: In re: : Chapter 11 : EHT US1, Inc., et al., : Case No. 21-10036 (CSS) : : (Jointly Administered) Debtors.1 : Hearing Date: September 24, 2021 at 11:00 a.m. (ET): Obj. Deadline: September 17, 2021 at 4:00 p.m. (ET) : ------------------------------------------------------------- xDEBTORS’ SECOND OMNIBUS OBJECTION (NON-SUBSTANTIVE) WITH RESPECT TO (I) CERTAIN DUPLICATE CLAIMS AND (II) CERTAIN AMENDED CLAIMS TO ALL PARTIES RECEIVING THIS OBJECTION: THIS OBJECTION SEEKS TO DISALLOW AND EXPUNGE CERTAIN CLAIMS. YOU SHOULD REVIEW EXHIBIT 1 AND EXHIBIT 2 TO THE PROPOSED ORDER TO LOCATE YOUR NAME AND CLAIM(S) AND TO DETERMINE IF YOUR CLAIM(S) ARE SUBJECT TO THIS OBJECTION. THE RELIEF SOUGHT IN THIS OBJECTION IS WITHOUT PREJUDICE TO THE RIGHTS OF THE DEBTORS, THEIR ESTATES, ANY SUCCESSORS THERETO OR ANY OTHER PARTY IN INTEREST TO PURSUE FURTHER OBJECTIONS AGAINST THE CLAIMS SUBJECT TO THIS OBJECTION, AND NOTHING HEREIN OR THE PROPOSED ORDER IS INTENDED OR SHALL BE DEEMED TO BE AN ALLOWANCE OF ANY SUCH CLAIMS. 1 The Debtors in these chapter 11 cases, along with the last four digits of each debtor’s tax identification number, as applicable, are as follows: EHT US1, Inc.(6703); 5151 Wiley Post Way, Salt Lake City, LLC (1455); ASAP Cayman Atlanta Hotel LLC (2088); ASAP Cayman Denver Tech LLC (7531); ASAP Cayman Salt Lake City Hotel LLC (7546); ASAP Salt Lake City Hotel, LLC (7146); Atlanta Hotel Holdings, LLC (6450); CI Hospitality Investment, LLC (7641); Eagle Hospitality Real Estate Investment Trust (7734); Eagle Hospitality Trust S1 Pte. Ltd. (7669); Eagle Hospitality Trust S2 Pte. Ltd. (7657); EHT Cayman Corp. Ltd. (7656); Sky Harbor Atlanta Northeast, LLC (6846); Sky Harbor Denver Holdco, LLC (6650); Sky Harbor Denver Tech Center, LLC (8303); UCCONT1, LLC (0463); UCF 1, LLC (6406); UCRDH, LLC (2279); UCHIDH, LLC (6497); Urban Commons 4th Street A, LLC (1768); Urban Commons Anaheim HI, LLC (9915); Urban Commons Bayshore A, LLC (2422); Urban Commons Cordova A, LLC (4152); Urban Commons Danbury A, LLC (4388); Urban Commons Highway 111 A, LLC (4497); Urban Commons Queensway, LLC (6882); Urban Commons Riverside Blvd., A, LLC (4661); and USHIL Holdco Member, LLC (4796). The Debtors’ mailing address is 3 Times Square, 9th Floor New York, NY 10036 c/o Alan Tantleff (solely for purposes of notices and communications).

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The above-captioned debtors (collectively, the “Debtors”), by and through the undersigned counsel, hereby file this omnibus objection (the “Objection”) and respectfully state as follows: RELIEF REQUESTED 1. By this Objection, the Debtors seek entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”) disallowing and expunging each of the Duplicate Claims (as defined herein) and Amended Claims (as defined herein) identified on Exhibit 1 and Exhibit 2 attached to the Proposed Order, respectively. In support of this Objection, the Debtors rely upon the Declaration of Charles Bradley Foster in Support of Relief Requested in Debtors’ Second Omnibus Objection (Non-Substantive) with Respect to (I) Certain Duplicate Claims and (II) Certain Amended Claims (the “Foster Declaration”), a copy of which is attached hereto as Exhibit B. In further support of this Objection, the Debtors respectfully represent as follows: JURISDICTION 2. This Court has jurisdiction over this Objection pursuant to 28 U.S.C. §§ 157 and 1334. This is a core proceeding under 28 U.S.C. § 157(b). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 3. The statutory predicates for the relief requested herein are section 502 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 3007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 3007-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”).

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4. Pursuant to Local Rule 9013-1(f), the Debtors consent to the entry of a final judgment or order with respect to this Objection if it is determined that this Court lacks Article III jurisdiction to enter such final order or judgment absent consent of the parties. BACKGROUND 5. On January 18, 2021, the Debtors (other than EH-REIT) commenced these chapter 11 cases by filing petitions for relief under chapter 11 of the Bankruptcy Code. EH-REIT commenced its chapter 11 case on January 27, 2021. The Debtors are managing and operating their businesses as debtors in possession pursuant to Bankruptcy Code sections 1107(a) and 1108. These chapter 11 cases are being jointly administered for procedural purposes only pursuant to Rule 1015(b) of the Federal Rules of Bankruptcy Procedure. 6. On February 4, 2021, the United States Trustee for Region 3 appointed the Official Committee of Unsecured Creditors of EHT US1, Inc. et al. (the “Committee”) to serve in these chapter 11 cases. By notice dated February 18, 2021, the U.S. Trustee amended the membership of the Committee. 7. A detailed description of the Debtors and their business is set forth in the Declaration of Alan Tantleff, Chief Restructuring Officer of Eagle Hospitality Group, in Support of Debtors’ Chapter 11 Petitions and First Day Motions [Docket No. 13] (the “First Day Declaration”), which is incorporated herein by reference.2 2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the First Day Declaration.

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SCHEDULES, PROOFS OF CLAIM, AND BAR DATES 8. On March 19-20, 2021, the Debtors filed their schedules of assets and liabilities and statements of financial affairs [Docket Nos. 403-458], certain of which were subsequently amended [Docket Nos. 728-733] on May 20, 2021 (collectively, the “Schedules”). 9. On April 9, 2021, the Court entered the Order (I) Fixing Deadlines for Filing Proofs of Claim and (II) Approving Form and Manner of Notice Thereof [Docket No. 560] (the “Bar Date Order”). Between April 19, 2021 and May 28, 2021, the Debtors served notices of bar dates for filing proofs of claim, including Section 503(b)(9) claims (the “Bar Date Notices”), as evidenced by the affidavits of service and publication filed with this Court [Docket Nos. 592-594, 601, 622, 652, 721, 792, and 801]. 10. The claims register for these chapter 11 cases, prepared and maintained by Donlin, Recano & Company, Inc., shows that over 900 proofs of claim have been filed against the Debtors as of the filing of this Objection. 11. In the ordinary course of business, the Debtors maintain books and records (the “Books and Records”) that reflect, among other things, the nature and amount of the liabilities owed to their creditors. The Debtors, with the assistance of their advisors, have actively begun reviewing and reconciling proofs of claim with the Debtors’ Schedules and Books and Records, which process includes identifying certain categories of claims that may be subject to objection and/or reclassification. While this analysis and reconciliation is ongoing, the Debtors have determined that the Duplicate Claims (as defined herein) and the Amended Claims (as defined herein) should be disallowed and expunged. Accordingly, the Debtors file this Objection seeking the relief requested below.

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12. To date, the Debtors have filed a total of one omnibus claims objection. [Docket No. 968.] DUPLICATE AND AMENDED CLAIMS A. Duplicate Claims 13. Each claim set forth on Exhibit 1to the Proposed Order under the column titled “Duplicate Claim to be Disallowed” (the “Duplicate Claims”) are duplicative of a proof of claim listed under the column titled “Remaining Claim Number” on Exhibit 1 (the “Remaining Claims”). The Debtor believes that it was not the intention of these claimants to assert multiple identical claims. Instead, the filing of the Duplicate Claims appears to be a function of the claimant filing multiple proofs of claim forms related to a single claim, or filing the same claim with multiple parties (e.g., the claims and noticing agent in these Chapter 11 Cases, the Debtors, counsel to the Debtors, or the Clerk of the Court). Regardless of the claimant’s reasons for filing the Duplicate Claims, at most, only one claim against the Debtors’ estates should be allowed for each claimant’s claim. Any failure to disallow the Duplicate Claims will result in the applicable claimant potentially receiving an unwarranted double recovery against the Debtors’ estates, to the detriment of other creditors in these chapter 11 cases. 14. Therefore, the Debtors object to the Duplicate Claims identified on Exhibit 1 attached to the Proposed Order and request entry of the Proposed Order disallowing and expunging the Duplicate Claims. 15. The Debtors reserve their rights, and the rights of any other party-in-interest entitled, to object to the Remaining Claims.

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B. Amended Claims 16. Each claim set forth on Exhibit 2 to the Proposed Order under the columns under the header “Amended Claim to be Disallowed” (the “Amended Claims,” and together with the Duplicate Claims, the “Claims”) are original versions of proofs of claim that were later revised or updated, the revised or updated version being listed under the columns under the header “Remaining Claim” on Exhibit 2 (the “Revised Claims”). The Debtors believe that it was not the intention of these claimants to assert multiple versions of the same claim (either against the same Debtor or against a different Debtor). Instead, the filing of the Amended Claims and Revised Claims appears to be a function of the claimant first filing a proof of claim form related to a single claim, and later filing a revised or updated version of that same claim, with the express or implied intention that the applicable Amended Claim be expunged and replaced by the applicable Revised Claims. Regardless of claimants’ reasons for filing the Amended Claims and Revised Claims, at most, only one version of the claim against the Debtors’ estates should be allowed for each claimant’s claim. Any failure to disallow the Amended Claims will result in the applicable claimant potentially receiving an unwarranted additional recovery against the Debtors’ estates, to the detriment of other creditors in these chapter 11 cases. 17. Therefore, the Debtors object to the Amended Claims identified on Exhibit 2 to the Proposed Order and request entry of the Proposed Order disallowing and expunging the Amended Claims. 18. The Debtors reserve their rights, and the rights of any other party-in-interest entitled, to object to the Revised Claims.

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BASIS FOR RELIEF REQUESTED 19. Section 502(a) of the Bankruptcy Code provides that “[a] claim or interest, proof of which is filed under section 501 of this title, is deemed allowed, unless a party in interest . . . objects.” 11 U.S.C. § 502(a). Once an objection to a claim is filed, the Court, after notice and a hearing, shall determine the allowed amount of the claim. See 11 U.S.C. § 502(b). 20. Section 502(b)(1) of the Bankruptcy Code provides, in part, that a claim may not be allowed to the extent that it “is unenforceable against the debtor and property of the debtor, under any agreement or applicable law.” 11 U.S.C. § 502(b)(1). While a properly filed proof of claim is prima facie evidence of the claim, when an objecting party rebuts a claim’s prima facie validity, the claimant bears the burden of proving the claim’s validity by a preponderance of evidence. See In re Allegheny Int’l, Inc., 954 F.2d 167, 173-74 (3d Cir. 1992). Ultimately, the burden of persuasion is on the claimant. Id. A. Duplicate Claims 21. The Duplicate Claims are unenforceable against the Debtors, and should be disallowed and expunged, for the reasons set forth above and in the Foster Declaration. Accordingly, the Debtors seek (a) to disallow and expunge the Duplicate Claims listed on Exhibit 1 to the Proposed Order and (b) entry of the Proposed Order disallowing and expunging the Duplicate Claims. Therefore, pursuant to section 502(b)(1) of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1, the Debtors respectfully request that the Court enter the Proposed Order granting the relief requested herein. B. Amended Claims 22. The Amended Claims are unenforceable against the Debtors, and should be disallowed and expunged, for the reasons set forth above and in the Foster Declaration.

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Accordingly, the Debtors seek (a) to disallow and expunge the Amended Claims listed on Exhibit 2 to the Proposed Order and (b) entry of the Proposed Order disallowing and expunging the Amended Claims. Therefore, pursuant to section 502(b)(1) of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1, the Debtors respectfully request that the Court enter the Proposed Order granting the relief requested herein. RESPONSES TO THIS OBJECTION 23. Filing and Service of Responses: To contest the Objection, a claimant must file and serve a written response to the Objection (a “Response”) so that it is actually received by the Clerk of the Court and the parties in the following paragraph no later than 4:00 p.m. (ET) on September 17, 2021 (the “Response Deadline”). Claimants should locate their names and claim(s) on Exhibit 1 and Exhibit 2 to the Proposed Order and carefully review the Objection. A Response must address each ground upon which the Debtors object to a particular claim. A hearing to consider the Debtors’ Objection, if necessary, will be held on September 24, 2021at 11:00 a.m. (ET), before the Honorable Christopher S. Sontchi, United States Bankruptcy Judge, via telephone or videoconference (the “Hearing”). Only those responses made in writing and timely filed and received will be considered by the Court at the Hearing. 24. Each Response should be filed with the Clerk of the United States Bankruptcy Court for the District of Delaware, 824 North Market Street, 3rd Floor, Wilmington, Delaware 19801, and served on counsel for the Debtors and the Committee, so that the response is received no later than the Response Deadline at the following addresses: (a) Paul Hastings LLP, 200 Park Avenue New York, New York 10166; (b) Cole Schotz P.C., 500 Delaware Avenue, Suite 1410 Wilmington, Delaware 19801; (c) Kramer Levin Naftalis & Frankel LLP, 1177 Avenue of the Americas, New York, New York 10036 (Attn: Adam C. Rogoff (arogoff@kramerlevin.com) and

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Douglas Buckley (dbuckley@kramerlevin.com)); and (d) Morris James LLP, 500 Delaware Avenue, Suite 1500, Wilmington, Delaware 19801 (Attn: Eric J. Monzo (emonzo@morrisjames.com) and Brya M. Keilson (bkeilson@morrisjames.com)). 25. Adjournment of Hearing: The Debtors reserve the right to seek an adjournment of the hearing on any Response to this Objection, which adjournment will be noted on the notice of agenda for the hearing. The agenda will be served on the person designated by the claimant in its Response. 26. Content of Responses: Each Response to this Objection must, at a minimum, contain the following information: i. a caption setting forth the name of the Court, the name of the Debtors, the case number, and the title of the Objection to which the Response is directed; ii. the name of the claimant, the claim number, and a description of the basis for the amount of the claim; iii. the specific factual basis and supporting legal argument upon which the party will rely in opposing this Objection; iv. all documentation and other evidence in support of the claim, not previously filed with the Court or the claims and noticing agent, upon which the claimant will rely in opposing this Objection; and v. the name, address, telephone number, fax number and/or email address of the person(s) (who may be the claimant or the claimant’s legal representative) with whom counsel for the Debtors should communicate with respect to the claim or the Objection and who possesses authority to reconcile, settle, or otherwise resolve the objection to the claim on behalf of the claimant. 27. If a claimant fails to timely file a Response by the Response Deadline, the Debtors may present to the Court an appropriate order disallowing and expunging or otherwise modifying the Claims without further notice to the claimant or a hearing.

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REPLIES TO RESPONSES 28. Consistent with Local Rule 9006-1(d), the Debtors may, at their option, file and serve a reply to a claimant’s response, if any, no later than 4:00 p.m. (ET) one day prior to the deadline for filing the agenda to consider this Objection. SEPARATE CONTESTED MATTERS 29. To the extent that a Response is filed regarding any claim that is the subject of this Objection and the Debtors are unable to resolve the Response, each such claim, and the objection to each such claim, asserted herein, shall constitute a separate contested matter as contemplated by Bankruptcy Rule 9014. Any order entered by the Court regarding any objection asserted in the Objection shall be deemed a separate order with respect to such claim. RESERVATION OF RIGHTS 30. The Debtors (and their estates) hereby reserve the right to object in the future to any of the proofs of claim listed in this Objection or on the Exhibits attached hereto on any ground, and to amend, modify, and/or supplement this Objection, including, without limitation, (i) to object to such claims on the basis that they are not properly asserted, or (ii) to object to amended and newly-filed claims. A separate hearing will be scheduled on any subsequently filed objection. 31. Notwithstanding anything contained in the Objection, or the exhibits attached hereto, nothing herein will be construed as a waiver of any rights that the Debtors, or any successor to the Debtors, may have to enforce rights of setoff against the claimants. 32. Nothing in this Objection shall be deemed: (a) an admission as to the amount of, basis for, or validity of any claim against the Debtors under the Bankruptcy Code or other applicable nonbankruptcy law; (b) a waiver of the Debtors’ or any other party in interest’s right

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to dispute any claim; (c) a promise or requirement to pay any particular claim; (d) an implication or admission that any particular claim is of a type specified or defined in this Objection; (e) an admission as to the validity, priority, enforceability, or perfection of any lien on, security interest in, or other encumbrance on property of the Debtors’ estates; or (f) a waiver of any of the Debtors’ claims or causes of action which may exist against any entity under the Bankruptcy Code or any other applicable law COMPLIANCE WITH LOCAL RULE 3007-1 33. To the best of the knowledge and belief of the undersigned counsel for the Debtors, this Objection, the Proposed Order, and the related Exhibit 1 and Exhibit 2, comply with Local Rule 3007-1. To the extent that this Objection does not comply in all respects with the requirements of Local Rule 3007-1, the undersigned believes such deviations are not material and respectfully requests that any such requirement be waived. NOTICE 34. Notice of this Objection has been provided to the following parties, or, in lieu thereof, their counsel: (i) the Office of the U.S. Trustee; (ii) counsel to the Committee; (iii) counsel to the lenders under the DIP Facility; (iv) the Internal Revenue Service; (v) the Securities and Exchange Commission; (vi) the United States Attorney for the District of Delaware; (vii) the claimants whose claims are subject to this Objection; and (viii) all parties who, as of the filing of this Objection, have filed a notice of appearance and request for service of papers pursuant to Bankruptcy Rule 2002. The Debtors submit that, in view of the facts and circumstances, such notice is sufficient and no other or further notice need be provided.

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NO PREVIOUS REQUEST 35. No previous request for the relief sought herein has been made by the Debtors to this or any other court. WHEREFORE, the Debtors respectfully request that the Court enter an order, substantially in the form attached hereto as Exhibit A, granting the relief sought herein and such other and further relief to the Debtors as the Court may deem proper. Dated: August 6, 2021 COLE SCHOTZ P.C. Wilmington, Delaware /s/ G. David Dean Seth Van Aalten (admitted pro hac vice) G. David Dean (No. 6403) Justin R. Alberto (No. 5126) 500 Delaware Avenue, Suite 1410 Wilmington, Delaware 19801 Telephone: (302) 652-3131 Facsimile: (302) 574-2103 Email: svanaalten@coleschotz.com ddean@coleschotz.com jalberto@coleschotz.com - and - PAUL HASTINGS LLP Luc A. Despins (admitted pro hac vice) G. Alexander Bongartz (admitted pro hac vice) 200 Park Avenue New York, New York 10166 Telephone: (212) 318-6000 Facsimile: (212) 319-4090 Email: lucdespins@paulhastings.com alexbongartz@paulhastings.com Counsel to Debtors and Debtors in Possession

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