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Full title: Objection // Objection, Joinder, and Reservation of Rights of Urban Commons, LLC, Constellation Hospitality Group, LLC, Howard Wu, and Taylor Woods to Debtors' Sale Motion (related document(s)334, 388, 503, 697, 722) Filed by Constellation Hospitality Group, LLC, Urban Commons, LLC, Taylor Woods, Howard Wu (Attachments: # 1 Exhibit A) (Stulman, Aaron) (Entered: 05/24/2021)

Document posted on May 23, 2021 in the bankruptcy, 4 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Howard Wu, Taylor Woods, Constellation Hospitality Group, LLC (“CHG”), and Urban Commons, LLC (collectively, the “Urban Commons Parties”), by and through their undersigned counsel, hereby file this objection and reservation of rights (the “Objection”) to the Motion of Debtors for Entry of Orders (I)Approving (A) Bidding Procedures, (B) Designation of Stalking Horse Bidder and Stalking Horse Bidder Protections, (C) Form and Manner of Notice Sale, Auctions, and Sale Hearing, and (D) Assumption and Assignment Procedures, (II) Scheduling Auctions and Sale Hearing, (III) Approving (A) Sale of Substantially All of Debtors’ Assets Free 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 (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).However, as has been previously stated, the Urban Commons Parties continue to believe, and assert, that the proposed sale transaction with the Successful Bidders does not maximize value for the Debtors’ estates, as was described in the Objection, Joinder, and Reservation of Rights of Urban Commons, LLC, Howard Wu, and Taylor Woods to Debtors’ Bidding Procedures and Sale Motion

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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: May 28, 2021 at 10:00 a.m. (ET) Objection Deadline: May 24, 2021 at 4:00 p.m. (ET) Re: Docket Nos. 334, 388, 503, 697 & 722 OBJECTION, JOINDER, AND RESERVATION OF RIGHTS OF URBAN COMMONS, LLC, CONSTELLATION HOSPITALITY GROUP, LLC, HOWARD WU, AND TAYLOR WOODS TO DEBTORS’ SALE MOTION Howard Wu, Taylor Woods, Constellation Hospitality Group, LLC (“CHG”), and Urban Commons, LLC (collectively, the “Urban Commons Parties”), by and through their undersigned counsel, hereby file this objection and reservation of rights (the “Objection”) to the Motion of Debtors for Entry of Orders (I) Approving (A) Bidding Procedures, (B) Designation of Stalking Horse Bidder and Stalking Horse Bidder Protections, (C) Form and Manner of Notice Sale, Auctions, and Sale Hearing, and (D) Assumption and Assignment Procedures, (II) Scheduling Auctions and Sale Hearing, (III) Approving (A) Sale of Substantially All of Debtors’ Assets Free 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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and Clear of Liens, Claims, Interests, and Encumbrances, and (B) Assumption and Assignment of Executory Contracts and Unexpired Leases, and (IV) Granting Related Relief [Docket No. 334] (the “Sale Motion”) and join in the objections to the Sale Motion filed by other parties-in-interest, to the extent not inconsistent herewith. In support of this Objection, Urban Commons Parties respectfully state as follows:2 OBJECTION 1. The Urban Commons Parties file this Objection to preserve their rights in connection with the deadline to file objections to the (i) identity of the Successful Bidders, (ii) conduct of the Auction, and (iii) Adequate Assurance, as set forth in the Bidding Procedures. The Urban Commons Parties have no objection to the conduct of the Auction or the Adequate Assurance provided by any of the Successful Bidders. 2. However, as has been previously stated, the Urban Commons Parties continue to believe, and assert, that the proposed sale transaction with the Successful Bidders does not maximize value for the Debtors’ estates, as was described in the Objection, Joinder, and Reservation of Rights of Urban Commons, LLC, Howard Wu, and Taylor Woods to Debtors’ Bidding Procedures and Sale Motion [Docket No. 388], Objection, Joinder, and Reservation of Rights of Urban Commons, LLC, Howard Wu, and Taylor Woods to Debtors’ Sale Motion [Docket No. 697], which arguments the Urban Commons Parties hereby incorporate in full as if set forth herein. 3. In contrast, a Chapter 11 Plan Bid represents the highest and best value to all stakeholders in these cases. In that vein, CHG timely submitted a Chapter 11 Plan Bid on May 2 All capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Sale Motion.

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14, 2021, and on May 19, 2021 filed the Emergency Motion of Constellation Hospitality Group, LLC (I) to Extend Certain of the Sale Deadlines, and (II) Granting Related Relief [Docket No. 722] (the “Motion to Adjourn”), which is attached hereto as Exhibit A and the factual background and arguments are incorporated in full herein.3 4. CHG is ardently trying to resolve the Debtors’ perceived infirmities with its Chapter 11 Plan Bid and aims to be in a position to present such revised Chapter 11 Plan Bid to the Debtors and the Court in advance of the Sale Hearing. 5. Relatedly, and in an abundance of caution, the Urban Commons Parties reiterate their request for a short adjournment of certain of the Sale deadlines to allow the potentially value-maximizing CHG bid to crystalize. As noted in the Motion to Adjourn, the Debtors do not need the consent of any party to adjourn the Sale Hearing to June 1, 2021. See Mot. to Adjourn ¶ 31 n.10. Accordingly, such an adjournment causes no perceived or actual harm or detriment to the Debtors’ estates, but such an adjournment could provide the runway needed by CHG to garner necessary support for its Chapter 11 Plan Bid and maximize value for these estates. JOINDER 6. The Urban Commons Parties join in the objections to the Sale Motion filed by other parties-in-interest, to the extent not inconsistent with this Objection. RESERVATION OF RIGHTS 7. Nothing contained herein shall constitute a waiver of any of the rights or remedies of Urban Commons Parties under the Bankruptcy Code or applicable law, including, without limitation, the right to supplement this Objection prior to the Sale Hearing or to otherwise assert 3 As the Court is aware, CHG also filed a motion to shorten the Motion to Adjourn, which was denied on May 19, 2021 [Docket No. 724].

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additional objections to the Sale Motion. Additionally, Urban Commons Parties reserve all rights to propound discovery in connection with this Objection and the Sale Motion. WHEREFORE, Urban Commons Parties respectfully request that the Court deny the Sale Motion at this time, adjourn the Sale Hearing as appropriate, and grant such other and further relief as the Court deems just and proper. Dated: May 24, 2021 Respectfully submitted, Wilmington, Delaware /s/ Aaron H. Stulman Christopher M. Samis (No. 4909) R. Stephen McNeill (No. 5210) 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 rmcneill@potteranderson.com astulman@potteranderson.com Counsel to Urban Commons, LLC, Constellation Hospitality Group, LLC, Howard Wu, and Taylor Woods

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