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Full title: Motion to Approve / Debtors' Motion for Order (I) Fixing Deadline for Filing Requests for Allowance of Post-Petition Administrative Expense Claims Arising on or before August 31, 2021, and (II) Designating Form and Manner of Notice Thereof Filed by EHT US1, Inc.. Hearing scheduled for 9/30/2021 at 11:00 AM at US Bankruptcy Court, 824 Market St., 5th Fl., Courtroom #6, Wilmington, Delaware. Objections due by 8/30/2021. (Attachments: # 1 Notice # 2 Exhibit A) (Dean, G.) (Entered: 08/16/2021)

Document posted on Aug 15, 2021 in the bankruptcy, 13 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

The debtors and debtors in possession in the above-captioned cases (the “Debtors”) file this motion (the “Motion”) for entry of an order, substantially in the form attached hereto as Exhibit A (the “Administrative Expense Bar Date Order”), pursuant to sections 102, 105(a), 503(a) and (b), and 507(a)(2) of title 11 of the United States Code (the “Bankruptcy Code”), Rules 2002(a), 3003(c), and 9007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rules 2002-1(e) and 3003-1(a) of the Local Rules of Bankruptcy 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.Except as otherwise provided herein, the Debtors propose that each entity, including, without limitation, individuals, partnerships, corporations, joint ventures, trusts, and governmental units, that holds or wishes to assert an administrative expense claim arising under sections 503(b) or 507(a)(2) of the Bankruptcy Code against the Debtors’ estates that arose during the Administrative Expense Claim Period (each, an “Administrative Expense Claim”) must file a motion or application with the Court requesting payment of such Administrative Expense Claim (each, a “Request for Payment”), no later than 5:00 p.m. (prevailing Eastern Time) on the date that is thirty-five (35) days after entry of the Administrative Expense Bar Date Order (such date, the “Administrative Expense Bar Date”).Pursuant to the terms of the proposed Administrative Expense Bar Date Order, the Debtors propose that each Request for Payment must: a) be signed by the claimant or, if the claimant is not an individual, by an authorized agent of the claimant; b) be written in the English language; c) be denominated in the currency of the United States; d) indicate the particular Debtor against which the claim is asserted; e) include all documentation that the claimant intends to rely upon at any evidentiary hearing on its Request for Payment; f) be timely filed with the Court on or before the Administrative Expense Bar Date with the Clerk of the Bankruptcy Court via the Bankruptcy Court’s CM/ECF System (for registered users) or by courier or United States mail to the Office of the Clerk, United States Bankruptcy Court for the District of Delaware, 3rdFloor, 824 Market Street, Wilmington, Delaware 19801; and g) be served so that it is actually received on or before the Administrative Expense Bar Date by the following co-counsels to the Debtors: (1) Paul Hastings LLP, 200 Park Avenue, New York, New York 10166 (Attn: Luc

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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) : Debtors.1 : (Jointly Administered) : : Hearing Date: September 30, 2021 at 11:00 a.m. (ET) : Obj. Deadline: August 30, 2021 at 4:00 p.m. (ET) ----------------------------------------------------------x DEBTORS’ MOTION FOR ORDER (I) FIXING DEADLINE FOR FILING REQUESTS FOR ALLOWANCE OF POST-PETITION ADMINISTRATIVE EXPENSE CLAIMS ARISING ON OR BEFORE AUGUST 31, 2021, AND (II) DESIGNATING FORM AND MANNER OF NOTICE THEREOF The debtors and debtors in possession in the above-captioned cases (the “Debtors”) file this motion (the “Motion”) for entry of an order, substantially in the form attached hereto as Exhibit A (the “Administrative Expense Bar Date Order”), pursuant to sections 102, 105(a), 503(a) and (b), and 507(a)(2) of title 11 of the United States Code (the “Bankruptcy Code”), Rules 2002(a), 3003(c), and 9007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rules 2002-1(e) and 3003-1(a) of the Local Rules of Bankruptcy 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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Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”): (a) fixing a deadline for filing of requests for allowance of Administrative Expense Claims (as defined below) that arose during the period from the Petition Date (as defined below) through and including August 31, 2021 (the “Administrative Expense Claim Period”), and (b) designating the form and manner of notice thereof. In support of this Motion, the Debtors respectfully represent as follows: PRELIMINARY STATEMENT 1. The Debtors commenced these chapter 11 cases approximately seven months ago. In the time since, the Debtors and their professionals have worked tirelessly to navigate and negotiate among major stakeholders a feasible and value-maximizing path forward. Currently, the Debtors are actively working with the official committee of unsecured creditors appointed in these cases (the “Committee”), the agent for the Debtors’ prepetition secured lenders (“Bank of America”), and various interested parties in these chapter 11 cases to facilitate a path for the Debtors to wind down the cases and to provide a distribution through a chapter 11 plan of liquidation to those parties. Indeed, the Debtors are in the process of preparing a draft plan term sheet that they intend to share with the Committee and Bank of America by mid-September 2021 as part of the process of formulating a chapter 11 plan. A key component of developing a chapter 11 plan will understanding the potential universe of administrative expense claims. As a result, the Debtors require complete and accurate information regarding the nature and amount of all outstanding administrative expense claims that will be asserted in these chapter 11 cases. 2. Accordingly, by this Motion, the Debtors propose to fix a bar date for certain administrative expense claims that arose during the Administrative Expense Claim Period. Fixing such a bar date will help the Debtors avoid any surprise administrative expenses that

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could otherwise interfere with the implementation and consummation of the Debtors’ chapter 11 plan within the necessary time period. As detailed herein, the Debtors propose a simple set of procedures for holders of alleged administrative expenses to file a request for payment. These procedures will also enable the Debtors to review and process asserted administrative expense claims in a timely manner that will preserve both estate and judicial resources. The proposed procedures will also allow for the prompt resolution of any disputed alleged administrative expense claims in advance of the effective date of a plan, thereby providing the maximum possible benefits to the liquidating debtors, prepetition secured lenders, and general unsecured creditors, to the extent such claims may be resolved in an amount less than the full asserted amounts. JURISDICTION 3. 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) and, pursuant to Local Rule 9013-1(f), the Debtors consent to the entry of a final order by the Court in connection with the Motion to the extent that it is later determined that the Court, absent consent of the parties, cannot enter final orders or judgments consistent with Article III of the United States Constitution. 4. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 5. The statutory bases for the relief requested are sections 102, 105(a), 503(a) and (b), and 507(a)(2) of the Bankruptcy Code, Bankruptcy Rules 2002(a), 3003(c), and 9007, and Local Rules 2002-1(e) and 3003-1(a).

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RELEVANT BACKGROUND 6. On January 18, 2021, the Debtors (other than Eagle Hospitality Real Estate Investment Trust (“EH-REIT”)) commenced these chapter 11 cases by filing petitions for relief under chapter 11 of the Bankruptcy Code (the “Initial Petition Date”). EH-REIT commenced its chapter 11 case on January 27, 2021 (the “EH-REIT Petition Date” and, together with the Initial Petition Date, as applicable, the “Petition Date”). 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. 7. On January 21, 2021 the Court entered an order approving the retention of Donlin, Recano & Company, Inc. (“Donlin & Recano”) as the claims and noticing agent in these chapter 11 cases [Docket No. 50]. Among other things, Donlin & Recano is authorized to receive, maintain, docket, and otherwise administer the proofs of claim filed in these chapter 11 cases and maintain the official claims register for each of the Debtors. 8. On February 4, 2021, the United States Trustee for Region 3 (the “U.S. Trustee”) appointed 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.2 9. On March 19-20, 2021, the Debtors filed their schedules of assets and liabilities and statements of financial affairs [Docket Nos. 403-58], certain of which were subsequently amended [Docket Nos. 728-33] on May 20, 2021 (collectively, the “Schedules”). 10. On April 9, 2021, the Court entered an order [Docket No. 560] (the “General Bar Date Order”) providing that all “claims” (as defined in section 101(5) of the Bankruptcy Code) 2 See Docket No. 243.

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of a person or entity (other than a governmental unit, as defined in section 101(27) of the Bankruptcy Code) arising before the applicable petition date (i.e., the EH-REIT Petition Date for claims against EH-REIT or the Petition Date for claims against all other Debtors) must file with Donlin & Recano their proofs of claim so that they are actually received on or before July 15, 2021 at 5:00 p.m. (prevailing Eastern time) (the “General Bar Date”). Notice of the General Bar Date, along with the other bar dates, was provided by mail and publication in accordance with the procedures outlined in the General Bar Date Order. See, e.g., Affidavit of Publication of Notice of Bar Dates for Filing Proofs of Claim, Including Section 503(b)(9) Claims [Docket No. 592]; Affidavit of Service [Docket No. 601]. 11. Pursuant to the General Bar Date Order, claims arising under section 503(b)(9) for the value of goods received by the Debtors within twenty (20) days of the commencement of their chapter 11 cases were specifically included in the General Bar Date. All other claims arising under section 503(b) and 507(a)(2) as administrative expenses were excluded, and the General Bar Date Order stated that such claims may be subject to a separate bar date. 12. To date, the Debtors have filed two omnibus objections to claims. See Docket Nos. 968 & 1015. RELIEF REQUESTED A. Establishment of the Administrative Expense Bar Date 13. Except as otherwise provided herein, the Debtors propose that each entity, including, without limitation, individuals, partnerships, corporations, joint ventures, trusts, and governmental units, that holds or wishes to assert an administrative expense claim arising under sections 503(b) or 507(a)(2) of the Bankruptcy Code against the Debtors’ estates that arose during the Administrative Expense Claim Period (each, an “Administrative Expense Claim”) must file a motion or application with the Court requesting payment of such Administrative

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Expense Claim (each, a “Request for Payment”), no later than 5:00 p.m. (prevailing Eastern Time) on the date that is thirty-five (35) days after entry of the Administrative Expense Bar Date Order (such date, the “Administrative Expense Bar Date”). 14. Pursuant to the terms of the proposed Administrative Expense Bar Date Order, the Debtors propose that each Request for Payment must: a) be signed by the claimant or, if the claimant is not an individual, by an authorized agent of the claimant; b) be written in the English language; c) be denominated in the currency of the United States; d) indicate the particular Debtor against which the claim is asserted; e) include all documentation that the claimant intends to rely upon at any evidentiary hearing on its Request for Payment; f) be timely filed with the Court on or before the Administrative Expense Bar Date with the Clerk of the Bankruptcy Court via the Bankruptcy Court’s CM/ECF System (for registered users) or by courier or United States mail to the Office of the Clerk, United States Bankruptcy Court for the District of Delaware, 3rdFloor, 824 Market Street, Wilmington, Delaware 19801; and g) be served so that it is actually received on or before the Administrative Expense Bar Date by the following co-counsels to the Debtors: (1) Paul Hastings LLP, 200 Park Avenue, New York, New York 10166 (Attn: Luc A. Despins (lucdespins@paulhastings.com) and G. Alexander Bongartz (alexbongartz@paulhastings.com); and (2) Cole Schotz P.C., 500 Delaware Avenue, Suite 1410, Wilmington, Delaware 19801 (Attn: Seth Van Aalten (svanaalten@coleschotz.com) and G. David Dean (ddean@coleschotz.com)). 15. In addition, the Debtors propose that responses to Requests for Payment shall be filed by 4:00 p.m. (ET) on the date that is fourteen (14) days from the Administrative Expense Bar Date (regardless of when the Request for Payment is filed), and any replies in further support of the Request for Payment be filed by 4:00 p.m. (ET) on the date that is seven (7) days from the

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date of any response. The Debtors further propose Requests for Payment that are timely filed and served, if any, be heard at the next omnibus hearing date on the Court’s calendar after the reply deadline, assuming the reply deadline precedes 4:00 p.m. (ET) on the day prior to the agenda due date (unless otherwise agreed between the Debtors and the claimant or ordered by the Court). 16. Notwithstanding anything to the contrary in this Motion, the Debtors propose that the Administrative Expense Bar Date shall not apply to the following: a) Administrative Expense Claims that have been previously paid by the Debtors in the ordinary course of business or otherwise; b) Administrative Expense Claims representing liabilities incurred in the ordinary course of the Debtors’ business including, among other things, wages, employee benefits, accounts payable, utility services, and insurance; c) Administrative Expense Claims previously filed with Donlin & Recano or the Court; d) Administrative Expense Claims for compensation for services rendered or reimbursement of expenses incurred by professionals retained in these chapter 11 cases pursuant to sections 327 or 1103 of the Bankruptcy Code or for persons seeking awards by the Bankruptcy Court of compensation for services rendered or reimbursement of expenses incurred under sections 330, 331, 503(b)(2), 503(b)(3), 503(b)(4), or 503(b)(5) of the Bankruptcy Code, including any ordinary course of business professionals retained pursuant to an order of this Court approving the employment of ordinary course business professionals; e) Any Administrative Expense Claims arising under section 503(b)(9) of the Bankruptcy Code for the value of goods received by the Debtors within twenty days of the commencement of these chapter 11 cases and for which the Bankruptcy Court previously entered an order establishing an earlier bar date for such claims; f) Any Administrative Expense Claims that are claims incurred in the ordinary course of business of the Debtors by any current officer or director of the Debtors or by DBS Trustee Limited, in its capacity as trustee for EH-REIT, including, for the avoidance of doubt, claims for

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reimbursement, contribution, and indemnification by such persons or entities arising from postpetition events; g) Any Administrative Expense Claims that are claims by any member of the Committee for reimbursement of expenses (including attorney fees) incurred in connection with the member’s service on the Committee; h) Any Administrative Expense Claims that are claims by any direct or indirect non-debtor subsidiary or affiliate of the Debtors; i) Any Administrative Expense Claims that are claims for fees payable to the Clerk of this Court; j) Any Administrative Expense Claims that are fees payable to the Office of the United States Trustee under 28 U.S.C. § 1930(a)(6) or accrued interest thereon arising under 31 U.S.C. § 3717; and k) Any Administrative Expense Claims that arise after the Administrative Expense Claim Period. 17. In the event that an entity purportedly holding an Administrative Expense Claim against the Debtors is required to file and serve a Request for Payment, but fails to do so properly or timely in accordance with the Administrative Expense Bar Date Order, the Debtors request that such party not be permitted to participate in any distribution in these chapter 11 cases on account of such Administrative Expense Claim, be forever barred, estopped and enjoined from asserting such Administrative Expense Claim against the Debtors, their chapter 11 estates, or any successor to the Debtors, and be prohibited from voting on or objecting to any chapter 11 plan for the Debtors on account of such Administrative Expense Claim. B. Notice of the Administrative Expense Bar Date 18. The Debtors also seek approval of the Debtors’ proposed notice of the Administrative Expense Bar Date, substantially in the form attached as Exhibit 1to the Administrative Expense Bar Date Order (the “Administrative Expense Bar Date Notice”).

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19. The Debtors, through Donlin & Recano, intend to serve a copy of the Administrative Expense Bar Date Notice within three (3) business day after entry of the Administrative Expense Bar Date Order (the “Service Date”) by first-class mail, postage prepaid, on the following parties: a) the U.S. Trustee; b) counsel for the Committee; c) all persons or entities that have requested notice of these proceedings in these chapter 11 cases pursuant to Bankruptcy Rule 2002; d) all person or entities that have filed claims against the Debtors; e) all known persons who have entered into a transaction with the Debtors on or after the Petition Date or that are known to hold a right to payment under section 503(b)(1) of the Bankruptcy Code; f) all parties to executory contracts and unexpired leases of the Debtors; g) all persons employed by the Debtors on or after the Petition Date; h) the attorneys of record for all parties with litigation pending against any of the Debtors; i) the Internal Revenue Service, the Securities and Exchange Commission, the United States Attorney’s Office for the District of Delaware, all taxing authorities for the jurisdictions in which any of the Debtors conduct business, and all other applicable governmental units; j) all other parties in the Debtors’ creditor matrix not included above;3and k) all parties who hold equity interests in EH-REIT. 3 For the avoidance of doubt, the Debtors’ mailing matrix includes, to the extent address information is available, parties that are not in contractual privity with the Debtors, but who dealt with the non-Debtor Master Lessees and other third parties in connection with the operation of the Hotels. The Debtors have limited information regarding the identities and addresses of such parties, and, accordingly, no assurance can be made that the Debtors’ lists of such parties (including address information) is complete.

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20. The Debtors will also cause the Administrative Expense Bar Date Notice to be posted by the Service Date on the website established by Donlin & Recano for the Debtors’ chapter 11 cases (https://www.donlinrecano.com/Clients/eagle/Index). BASIS FOR RELIEF 21. Although the Debtors have been paying their ordinary course postpetition liabilities as they come due, the goal of this Motion is to “shake the trees” before the Debtors continue the process of drafting the plan term sheet and negotiating a chapter 11 plan, as part of an effort to ascertain whether any other administrative obligations may be outstanding. Knowing the full extent of any potential administrative obligations at this time will help ensure that the Debtors are able to successfully finalize a plan. Accordingly, the Debtors submit that entry of the Administrative Expense Bar Date Order is appropriate at this time. 22. Section 503 of the Bankruptcy Code provides that “an entity may timely file a request for payment of an administrative expense,” which request for payment may be allowed “[a]fter notice and a hearing.” 11 U.S.C. § 503(a)-(b). In addition, the General Bar Date Order expressly provided that it did not apply to “any holder of a claim allowable under sections 503(b) and 507(a)(2) of the Bankruptcy Code as an expense of administration of the Debtors’ estate.”423. Bankruptcy Rule 3003(c)(3) provides, in pertinent part, that “the court shall fix and for cause shown may extend the time within which proofs or claim or interest may be filed.” Fed. R. Bankr. P. 3003(c)(3). Similarly, Local Rule 2002-l(e) provides that “[i]n all cases under chapter 11, the debtor may request a bar date for the filing of proofs of claim or interests.” Del. Bankr. L.R. 2002-1(e). 4 General Bar Date Order § 7(d).

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24. Bankruptcy Rule 9007 provides that when the time for notice is not otherwise specified by the Bankruptcy Rules, “the court shall designate . . . the time within which, the entities to whom, and the form and manner in which the notice shall be given.” Fed. R. Bankr. P. 9007. 25. As can be seen, neither the Bankruptcy Rules nor the Local Rules specify the time by which requests for payment of administrative expense claims must be filed in a chapter 11 case. As a result, the Court has discretion in setting such a date and is authorized to grant the relief requested in this Motion. See 11 U.S.C. § 102 (defining “notice and a hearing” as “such notice as is appropriate in the particular circumstances, and such opportunity for a hearing as is appropriate in the particular circumstances”); see also 11 U.S.C. § 105(a) (empowering a court to issue “any order, process, or judgment that is necessary or appropriate to carry out the provisions of the Bankruptcy Code”). 26. Additionally, courts in this District have established Administrative Expense Bar Dates and granted relief similar to that requested herein. See, e.g., In re CR Liquidating, Inc., et al., No. 19-10210 (Bankr. D. Del. Nov. 1, 2019) [Docket No. 1063]; In re Videology, Inc., et al., No. 18-11120 (BLS) (Bankr. D. Del. Aug. 27, 2018) [Docket No. 422]; In re Eastern Outfitters, LLC, No. 17-10243 (LSS) (Bankr. D. Del. Apr. 24, 2017) [Docket No. 456]; In re General Wireless Operations Inc., No. 17-10506 (BLS) (Bankr. D. Del. May 23, 2017) [Docket No. 651]; In re Baxano Surgical, Inc., No. 14-12545 (CSS) (Bankr. D. Del. Jun. 1, 2015) [Docket No. 487]. 27. As noted above, the Debtors will provide parties in interest with thirty days’ notice of the Administrative Expense Bar Date. The Debtors respectfully submit that the

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Administrative Expense Bar Date Notice and proposed form and manner of service thereof provide sufficient notice to parties in interest of the Administrative Expense Bar Date. 28. For the reasons discussed above, the Debtors respectfully submit that it is appropriate for the Court to establish the Administrative Expense Bar Date. The Administrative Expense Bar Date will give possible holders of Administrative Expense Claims a reasonable time after receiving the Administrative Expense Bar Date Notice to file a Request for Payment. Moreover, fixing the Administrative Expense Bar Date will enable the Debtors to address any Administrative Expense Claims in a timely and efficient manner and allow for the prompt payment of legitimate Administrative Expense Claims. 29. Accordingly, the Debtors respectfully submit that the relief requested in this Motion is in the best interest of their creditors, their estates, and all parties in interest. NOTICE 30. Notice of this Motion 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) the United States Attorney for the District of Delaware; (iv) the Internal Revenue Service; and (v) all parties who, as of the filing of this Motion, 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. NO PRIOR REQUEST 31. No prior request for the relief sought herein has been made to the Court or any other court.

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WHEREFORE, the Debtors respectfully requests that the Court grant the Motion and enter an order, substantially in the form attached hereto as Exhibit A, granting the relief requested herein and granting the Debtor such other and further relief as is just and proper. Dated: August 16, 2021 Wilmington, Delaware COLE SCHOTZ P.C. /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) 652-3117 Email: svanaalten@coleschotz.com ddean@coleschotz.com jalberto@coleschotz.com - and - PAUL HASTINGS LLP Luc A. Despins, Esq. (admitted pro hac vice) G. Alexander Bongartz, Esq. (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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