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Full title: Reply in Support of Motion of Potter Anderson & Corroon LLP for Leave to Withdraw as Counsel to Urban Commons, LLC, its Affiliated Entities, Constellation Hospitality Group, LLC, Howard Wu and Taylor Woods (related document(s)910, 942, 999, 1002) Filed by Constellation Hospitality Group, LLC, Urban Commons, LLC, Taylor Woods, Howard Wu (Attachments: # 1 Certificate of Service) (Stulman, Aaron) (Entered: 08/09/2021)

Document posted on Aug 8, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Re: Docket Nos. 910, 942, 999, & 1002 REPLY IN SUPPORT OF MOTION OF POTTER ANDERSON & CORROON LLP FOR LEAVE TO WITHDRAW AS COUNSEL TO URBAN COMMONS, LLC, ITS AFFILIATED ENTITIES, CONSTELLATION HOSPITALITY GROUP, LLC, HOWARD WU AND TAYLOR WOODS Potter Anderson & Corroon LLP (“Potter Anderson”), counsel to EHT HIDH, LLC, EHT ESAN, LLC, EHT RDH, LLC, EHT HISM, LLC, EHT HIOR, LLC, EHT SPH, LLC, EHT ESPD, LLC, EHT HIA, LLC, EHT FPSJ, LLC, EHT WSAC, LLC, EHT CPDCT, LLC, EHT QMLB, LLC, EHT HAN, LLC, EHT DHSLC, LLC, EHT SDTC, LLC, EHT CPDGA, LLC, EHT HHG, LLC, EHT RWH, LLC, EHT Asset Management, LLC, Urban Commons, LLC, Constellation Hospitality Group, LLC (“CHG”), Howard Wu, and Taylor Woods (collectively, the “Urban Commons Parties”) in the bankruptcy cases (the “Chapter 11 Cases”) of the above-captioned debtors and debtors in possession (the “Debtors”) and in twenty-five (25) related adversary 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.EHT Cayman Corp. Ltd. (7656); Sky Harbor Atlanta Northeast, LLC (6450); 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 (3292); 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).Counsel to Urban Commons, LLC and its Affiliated Entities, Constellation Hospitality Group, LLC, Howard Wu, and Taylor Woods

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 EHT US1, Inc., et al.,1 Case No. 21-10036 (CSS) Debtors. (Jointly Administered) Hearing Date: August 12, 2021 at 11:00 a.m. (ET) Re: Docket Nos. 910, 942, 999, & 1002 REPLY IN SUPPORT OF MOTION OF POTTER ANDERSON & CORROON LLP FOR LEAVE TO WITHDRAW AS COUNSEL TO URBAN COMMONS, LLC, ITS AFFILIATED ENTITIES, CONSTELLATION HOSPITALITY GROUP, LLC, HOWARD WU AND TAYLOR WOODS Potter Anderson & Corroon LLP (“Potter Anderson”), counsel to EHT HIDH, LLC, EHT ESAN, LLC, EHT RDH, LLC, EHT HISM, LLC, EHT HIOR, LLC, EHT SPH, LLC, EHT ESPD, LLC, EHT HIA, LLC, EHT FPSJ, LLC, EHT WSAC, LLC, EHT CPDCT, LLC, EHT QMLB, LLC, EHT HAN, LLC, EHT DHSLC, LLC, EHT SDTC, LLC, EHT CPDGA, LLC, EHT HHG, LLC, EHT RWH, LLC, EHT Asset Management, LLC, Urban Commons, LLC, Constellation Hospitality Group, LLC (“CHG”), Howard Wu, and Taylor Woods (collectively, the “Urban Commons Parties”) in the bankruptcy cases (the “Chapter 11 Cases”) of the above-captioned debtors and debtors in possession (the “Debtors”) and in twenty-five (25) related adversary 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 (6450); 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 (3292); 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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proceedings (the “Adversary Proceedings” and, with the Chapter 11 Cases, the “Proceedings”), hereby files this reply (the “Reply”) in support of its motion to withdraw as counsel [Docket No. 910] (the “Motion to Withdraw”) and in response to the objection filed by Taylor Woods [Docket No. 942] (the “Woods Objection”), the objection filed by the Official Committee of Unsecured Creditors [Docket No. 999] (the “Committee Objection”), and the response filed by the Debtors [Docket No. 1002] (the “Debtors Response”), and respectfully states as follows: REPLY 1. Since the filing of the Motion to Withdraw, and as of the date hereof, Potter Anderson has not received any further payment. As such, for the reasons set forth in the Motion, the Woods Objection, and its request to refrain from ruling on the Motion to Withdraw for “30-60 days”, should be overruled. Potter Anderson cannot continue to work without being paid. 2. Additionally, Potter Anderson has received, in writing, confirmation from the document management company (the “Document Management Company”), that is hosting the documents collected from the Urban Commons Parties in connection with the discovery requests in the Proceedings, that all documents collected from the Urban Commons Parties will be preserved. This should resolve the Debtors Response and largely resolve the Committee Objection. 3. However, as was conveyed to the parties, Potter Anderson has learned that the Document Management Company has outstanding invoices that have not been paid and accordingly, it will not incur any additional expenses absent payment, which includes transmitting the documents it is holding and preserving, running search terms, or producing documents. While the Committee argues, without support, that certain of its requests are for documents that “do not require extensive review prior to production” and that Potter Anderson “should produce any such 2

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documents prior to being relieved as counsel”, Potter Anderson cannot physically complete such work given the current issues with the Document Management Company. See Committee Objection ¶ 6. Even if it could review and produce responsive documents, Potter Anderson should not be required to continue to work without being paid regardless of whether the Committee deems the review “extensive” or not. Potter Anderson respectfully requests that the Committee Objection, to the extent it is not resolved by the preservation of documents discussed above, be overruled. WHEREFORE, undersigned counsel respectfully requests that the Court (i) enter an order, substantially in the form attached to the Motion as Exhibit A, granting Potter Anderson leave to withdraw as counsel to the Urban Commons Parties in the Proceedings, and (ii) grant such other and further relief as the Court deems just and proper. Dated: August 9, 2021 Respectfully submitted, Wilmington, Delaware /s/ Aaron H. Stulman Christopher M. Samis (No. 4909) Aaron H. Stulman (No. 5807) POTTER ANDERSON & CORROON LLP 1313 N. Market Street, 6th Floor Wilmington, Delaware 19801 Telephone: (302) 984-6000 Facsimile: (302) 658-1192 Email: csamis@potteranderson.com astulman@potteranderson.com Counsel to Urban Commons, LLC and its Affiliated Entities, Constellation Hospitality Group, LLC, Howard Wu, and Taylor Woods 3

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