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Full title: Response in Support of Motion to Dismiss Case filed by Whitney L Mosby on behalf of Creditor Official Committee of Unsecured Creditors of Gregg (re: Doc # 3147). (Mosby, Whitney) (Entered: 04/15/2021)

Document posted on Apr 14, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

INC. IN SUPPORT OF THE APPROVAL OF THE DEBTORS’ MOTION FOR ENTRY OF AN ORDER (I) DISMISSING THE DEBTORS’ CHAPTER 11 CASES; (II) ESTABLISHING CASE WIND DOWN PROCEDURES TO CLAIMS RECONCILIATION, PROFESSIONAL FEES AD FINAL FEE APPLICATIONS; (III) DIRECTING THE DEBTOR ENTITIES TO BE DISSOLVED; AND (IV)The Official Committee of Unsecured Creditors (the “Committee”) of the above-captioned debtors and debtors-in-possession (collectively, the “Debtors”), by and through its undersigned counsel, hereby files this response (the “Response”) in support of the approval of the Debtors’ Motion for Entry of an Order (I)To that end, the Committee and its professional advisors have 1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, are: hhgregg, Inc. (0538); Gregg Appliances, Inc. (9508); andThe location of the Debtors’ corporate headquarters is 755 W. Carmel Drive, Suite 207, Carmel, IN 46032.Taking into account that there are insufficient funds to satisfy the estates’ priority claims (much less general unsecured claims) even if the liquidation of the remaining assets yields recoveries at the higher end of estimates, the Committee has determined that the relief requested in the Motion to Dismiss merits this Court’s approval and provides closure to all stakeholders without unreasonable delay.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION In re: Chapter 11 hhgregg, Inc., et al.,1 Case No. 17-01302-RLM-11 Debtors. (Jointly Administered) RESPONSE OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF GREGG APPLIANCES, INC. IN SUPPORT OF THE APPROVAL OF THE DEBTORS’ MOTION FOR ENTRY OF AN ORDER (I) DISMISSING THE DEBTORS’ CHAPTER 11 CASES; (II) ESTABLISHING CASE WIND DOWN PROCEDURES TO CLAIMS RECONCILIATION, PROFESSIONAL FEES AD FINAL FEE APPLICATIONS; (III) DIRECTING THE DEBTOR ENTITIES TO BE DISSOLVED; AND (IV) GRANTING RELATED RELIEF The Official Committee of Unsecured Creditors (the “Committee”) of the above-captioned debtors and debtors-in-possession (collectively, the “Debtors”), by and through its undersigned counsel, hereby files this response (the “Response”) in support of the approval of the Debtors’ Motion for Entry of an Order (I) Dismissing the Debtors’ Chapter 11 Cases; (II) Establishing Case Wind Down Procedures to Claims Reconciliation, Professional fees and Final Fee applications; (III) Directing the Debtor Entities to be Dissolved; and (IV) Granting Related Relief (the “Motion to Dismiss”) [Docket No. 3147].2 In support of this Response, the Committee respectfully submits as follows: 1. The Committee’s goal throughout these cases has been to seek the best possible outcome for unsecured creditors. To that end, the Committee and its professional advisors have 1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, are: hhgregg, Inc. (0538); Gregg Appliances, Inc. (9508); and HHG Distributing LLC (5875). The location of the Debtors’ corporate headquarters is 755 W. Carmel Drive, Suite 207, Carmel, IN 46032. 2 Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Motion to Dismiss.

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been actively involved in all aspects of these chapter 11 cases, including the oversight of the prosecution of the Litigation Claims, which are one of the few remaining assets of the Debtors. Taking into account that there are insufficient funds to satisfy the estates’ priority claims (much less general unsecured claims) even if the liquidation of the remaining assets yields recoveries at the higher end of estimates, the Committee has determined that the relief requested in the Motion to Dismiss merits this Court’s approval and provides closure to all stakeholders without unreasonable delay. The Committee, therefore, supports the structured dismissal procedures proposed in the Motion to Dismiss and believes that it is best to wind down the estates as set forth therein given the facts and circumstances of these cases. 2. This Response does not, in any way, prohibit or limit any Committee member from taking a separate or different position in its individual capacity, or participating in the proceedings in its individual capacity as to the Motion to Dismiss or any other matter before the Court. WHEREFORE, the Committee hereby requests that the Court (i) approve the Motion to Dismiss and (ii) grant such other and further relief as the Court deems just. Dated: April 15, 2021 Respectfully submitted, /s/ Whitney L. Mosby Whitney L Mosby (No. 23691-49) DENTONS BINGHAM GREENEBAUM LLP 2700 Market Tower 10 W. Market Street Indianapolis, IN 46204 Telephone: 317-635-8900 Facsimile: 317-236-9907 whitney.mosby@dentons.com - and -

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COOLEY LLP Cathy Hershcopf (admitted pro hac vice) Summer M. McKee (admitted pro hac vice) 55 Hudson Yards New York, NY 10001 Telephone: (212) 479-6000 Facsimile: (212) 479-6275 Email: chershcopf@cooley.com smckee@cooley.com Counsel to the Official Committee of Unsecured Creditors of Gregg Appliances, Inc. CERTIFICATE OF SERVICE I hereby certify that on April 15, 2021, I electronically filed the foregoing. Notice of this filing will be sent to the parties who have requested to receive notice through the Court’s Electronic Case Filing System. Parties may access this filing through the Court’s system. I further certify that on April 15, 2021, a copy of the foregoing was mailed by first-class U.S. Mail, postage prepaid and properly addressed, to the following: N/A /s/ Whitney L. Mosby Whitney L. Mosby

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