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Full title: Notice of Hearing and Motion for Order (I) Granting Expedited Relief and (II) Approving the Debtor's Proposed Notice Procedures for Employees, Enrollees in the Debtor's Customer Programs, and Gift Card Holders. filed by Tea Olive I, LLC . An affidavit or verification, Memorandum of law, Proposed order. Hearing scheduled 1/13/2021 at 02:00 PM at *TELEPHONIC HEARING* with Judge William J. Fisher (St Paul). (Barbie MNBS) (Entered: 01/11/2021)

Document posted on Jan 10, 2021 in the bankruptcy, 20 pages and 0 tables.

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037 Chapter 11 Case Debtor. NOTICE OF HEARING AND MOTION FOR ORDER (I) GRANTING EXPEDITED RELIEF AND (II) APPROVING THE DEBTOR’S PROPOSED NOTICE PROCEDURES FOR EMPLOYEES, ENROLLEES IN THE DEBTOR’S CUSTOMER PROGRAMS, AND GIFT CARD HOLDERS 1. Tea Olive I, LLC d/b/a Stock+Field (the “Debtor”) moves the Court for the relief requested below and give notice of hearing. 2. The Court will hold a hearing on this Motion at 2:00 p.m. (CT) on Wednesday, January 13, 2021, in Courtroom 2B, 232 Warren E. Burger Federal Building and U.S. Courthouse, 316 North Robert Street, St. Paul, MN 55101. The hearing will be held telephonically: a. Dial 1-888-684-8852; b. When prompted, enter ACCESS CODE: 5988550; c. When prompted, enter SECURITY CODE: 0428. 3. Local Rule 9006-1(b) and the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) provides deadlines for responses to this Motion. However, given the expedited nature of the relief sought in the Motion, the Debtor does not object to written responses being served and filed two hours prior to the hearing. UNLESS A RESPONSE OPPOSING THE MOTION IS TIMELY FILED, THE COURT MAY GRANT THE MOTION WITHOUT A HEARING.

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4. This Court has jurisdiction over this Motion pursuant to 28 U.S.C. §§ 157 and 1334, Bankruptcy Rule 5005, and Local Rule 1070-1. This is a core proceeding. The petition commencing this chapter 11 case was filed on January 10, 2021 (the “Filing Date”). The case is now pending before this Court. 5. This Motion arises under section 105(a) of the Bankruptcy Code, Bankruptcy Rule 2002, and Local Rules 2002-1, 2002-4, 9029-1. This Motion is filed under Bankruptcy Rule 6004 and 9014 and Local Rules 9013-1 through 9013-3. The Debtor requests expedited relief and an order establishing certain notice procedures (the “Notice Procedures”) for providing notice to current and former employees, enrollees in the Debtor’s various customer programs, and gift card holders. BACKGROUND 6. On the Filing Date, the Debtor filed a voluntary petition for relief pursuant to chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”). The Debtor continues to operate its business as debtor in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in the Debtor’s chapter 11 case. No creditors’ or other official committee has yet been appointed pursuant to section 1102 of the Bankruptcy Code. 7. Further general background information about the Debtor and this case is set forth in the Declaration of Matthew F. Whebbe in Support of Chapter 11 Petition and Initial Motions. The additional facts relevant to this Motion are set forth below and are verified by Matthew Whebbe, as evidenced by the attached verification. 8. By this Motion, the Debtor seeks approval of and authorization to adopt Notice Procedures for three categories of individuals:

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a. Current and former employees (dating back 12 months), which number is in excess of 1,000 individuals (the “Employee Group”); b. Individuals who are enrolled in the AG Plus Rewards Program, the Stock+Field Rewards Program, and other customer programs1 (the “Customer Program Group”); and c. Gift card holders, whose identities and contact information are unknown, but the face dollar value of outstanding prepetition gift cards totals over $384,228 (the “Gift Card Group”). 9. With regard to the Employee Group, some but likely not all of the Debtor’s past and present employees are creditors.2 Nevertheless, in some chapter 11 cases, current and past employees are listed on creditor matrices. The Debtor, however, would like to protect its employees’ personal contact information (including their home addresses) and simplify the service of documents on these individuals. The Debtor’s proposed Notice Procedures include a method to provide these individuals with adequate notice without supplying personal information in any public filed documents, all at a lower cost than traditional service. Obtaining the approval of a procedure such as this is particularly important here, given that the Employee Group includes over 1,000 individuals. If the Debtor or the Clerk of Court (via the bankruptcy notice center) was required to serve full pleadings or orders on this group, it would be very expensive. Furthermore, as a practical matter, many in the Employee Group likely will have no interest in reviewing the 1 For a full explanation of the Debtor’s customer programs, see Notice of Hearing and Motion for Order (I) Granting Expedited Relief and (II) Authorizing the Debtor to Honor and Continue Certain Customer Programs and Customer Obligations in the Ordinary Course of Business that the Debtor is filing contemporaneously with this Motion. 2 Contemporaneously with this Motion, the Debtor is filing a motion seeking authorization to pay prepetition compensation and benefits to current employees, which, if granted, greatly reduces the likelihood that current employees will be creditors.

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documents or participating in the case; if they do, however, the Notice Procedures would provide them the opportunity. 10. With regard to the Customer Program Group, the Debtor does not believe these individuals are creditors.3 Nevertheless, the Debtor would like to keep the Customer Program Group informed about the case and, therefore, includes proposed Notice Procedures for these individuals. The Notice Procedures for this group contemplates (a) sending an e-mail notification, to the extent the Debtor is in possession of a valid e-mail address, or a written notification by U.S. mail to the Ag Plus members, (b) working with the company administering the Stock+Field Mastercard Program to notify holders of the credit card through their regular credit card statements, or (c) to the extent the other options are not successful, a short notice, likely in the form of a postcard, to be mailed by the Debtor’s claims and noticing agent. 11. For the Gift Card Group, the Debtor does not have and cannot obtain information regarding the identities of the members of this group; consequently, the Debtor’s proposed Notice Procedures provides for publishing notice of the commencement of this case in a national newspaper and for notices to be posted on the Debtor’s website, in-store, mass e-mails to customer lists, and social media outreach. 12. The Notice Procedures proposed below, if approved, will save the estate (and the bankruptcy noticing center) resources that would otherwise be spent copying and paying for postage for thousands of pages for service copies of documents that would be sent to thousands or tens of thousands of individuals. While saving time and resources, the Notice Procedures will still provide for good and adequate notice – arguably better than traditional notice, in light of the 3 All of the customer programs are subject to certain restrictions and are not redeemable for cash.

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circumstances and recipients – to the Employee Group, the Customer Program Group, and the Gift Card Group. RELIEF REQUESTED 13. By this Motion, the Debtor seeks entry of an order approving as adequate, and authorizing the Debtor to adopt, the following Notice Procedures: a. Employee Group. The Debtor proposes that, to protect the privacy and personal information of the Employee Group, individuals in the Employee Group will not be listed on the creditor matrix. Instead, the Debtor proposes to serve, by U.S. mail, on each individual in the Employee Group: (a) a copy of the notice of case commencement that will be issued by the office of the Clerk of Court; and (b) a Notice of Filing Motion or Other Document, substantially in the form attached hereto as Exhibit A, for any motions or documents that the Debtor files that are required to be served on the full creditor matrix, where such notice will provide employees with the name of the motion or other document, the date by which any objection must be filed, the date of the hearing on the motion and the location of the hearing, and the address for the Debtor’s case information website maintained by the Debtor’s claims and noticing agent, which will have available for download (at no charge) a copy of the Debtor’s full docket, including the particular motion at issue in the notice. The office of the Clerk of Court will not be required to mail to the Employee Group any subsequent order on such a motion or other document; rather, as stated on the Notice of Filing Motion or Other Document, the order would be accessible on the Debtor’s case information website. If any envelope sent to individuals in the Employee Group are returned as undeliverable with no forwarding address, the Debtor will not be required to include those individuals in any future mailings to the Employee Group.

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Within seven business days of each mailing described herein being served, the Debtor will file a certificate of service that lists the first and last name of each individual served, with addresses redacted. The Debtor will maintain, but not file, a copy of the certificate of service with unredacted addresses. b. Customer Program Group. As noted above, the Debtor does not believe that the individuals in the Customer Program Group are creditors. Thus, the Debtor does not intend to list them on the creditor matrix, and does not believe notice is required. Nevertheless, out of an abundance of caution and in order to enable the Customer Program Group to be informed about the commencement of this case, the Debtor proposes to: (a) e-mail or mail by U.S. mail the notice of case commencement to all members of the Ag Plus program, depending on whether the Debtor has an e-mail address or physical address for such member; (b) work with the administrator of the Stock+Field Mastercard Program to include an insert in the next monthly credit card statement mailed after the Filing Date notifying the cardholder of the bankruptcy filing; or (c) if the credit card administrator will not or cannot include the insert in the credit card statement for no or a nominal cost, the Debtor will mail a postcard notice to the cardholders. The insert or postcard will provide notice of the commencement of the case, and provide the address for the Debtor’s case information website maintained by the claims and noticing agent, which will have available for download (at no charge) a copy of the Debtor’s full docket. If notice is provided via option (b), the Debtor will file a certificate of service attaching a copy of the insert, and in which the administrator certifies that the insert was added to the credit card statements, the date(s) the statements were sent, and the approximate number of statements sent with the insert. If notice is provided via option (c), the Debtor will file a certificate of service

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attaching a copy of the postcard, and indicating the date the postcards were sent, the approximate number sent, and the custodian of the records containing the names and addresses. c. Gift Card Group. As noted above, the Debtor has no identifying information about the holders of gift cards. Thus, the Debtor proposes to provide notice through publication of the notice in a national publication and through publication of the notice on its website, in-store, in mass e-mails to customer lists, and through social media outreach. Specifically, the Debtor proposes to provide notice of the commencement of the case (which would also note the proof of claim deadline and the address for the Debtor’s case information website maintained by the claims and noticing agent) by publishing the notice in a national newspaper (such as USA Today, New York Times, or the Wall Street Journal) within 10 after the entry of the order granting this Motion. The Debtor also proposes to physically post a printed notice in each retail store within 10 days after the entry of the order granting this Motion, which will remain posted for one month from the date of posting (unless the store closes sooner). The Debtor further intends to provide notice of the commencement of the case by posting the information on the Debtor’s website, sending an e-mail to the Debtor’s customer distribution lists, publishing posts on the Debtor’s social media platforms, and coordinating with the store closing consultant to also publish notice through the store closing consultant’s various notification methods. EXPEDITED RELIEF 14. The Debtor requests expedited relief on this motion. The granting of this motion on an expedited basis will allow the Debtor to use the Notice Procedures for notice of the case filing and the motions that will be filed in the coming days.

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15. Pursuant to Local Rule 9013-2, this Motion is verified and is accompanied by a Memorandum of Law, proposed order and proof of service. 16. Pursuant to Local Rule 9013-2, the Debtor gives notice that it may, if necessary, call one or more of the following to testify regarding the facts set forth in this Motion: (a) Matthew Whebbe, the Chief Executive Officer of the Debtor, whose business address is 2600 Eagan Woods Drive, Suite 120, Eagan, MN 55121 and (b) Michael Wesley, a Partner at Clear Thinking Group, the Chief Restructuring Officer and Financial Advisor to the Debtor, whose business address is 401 Towne Centre Drive, Hillsborough, NJ 08844. WHEREFORE, the Debtor respectfully moves the Court for an order A. Granting expedited relief; B. Approving the Notice Procedures as providing good, adequate, and sufficient notice; C. Authorizing the Debtor to adopt the Notice Procedures; and D. Granting such other and further relief as the Court deems just and equitable. Dated: January 11, 2021 /s/ Steven R. Kinsella Clinton E. Cutler (#0158094) James C. Brand (#0387362) Steven R. Kinsella (#0392289) Samuel M. Andre (#0399669) FREDRIKSON & BYRON, P.A. 200 South Sixth Street, Suite 4000 Minneapolis, MN 55402-1425 (612) 492-7000 ccutler@fredlaw.com jbrand@fredlaw.com skinsella@fredlaw.com sandre@fredlaw.com PROPOSED ATTORNEYS FOR THE DEBTOR

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EXHIBIT A

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037 Chapter 11 Case Debtor. NOTICE OF FILING MOTION OR OTHER DOCUMENT TO: Employees and Former Employees of Tea Olive I, LLC d/b/a Stock+Field 1. A [motion OR document] entitled [TITLE] was filed on [DATE], in the above-referenced case. 2. To see full copy of the [motion OR document] (without charge), please go to www.donlinrecano.com/sf. 3. If you would like to respond to the [motion OR document], your response must be filed and served on or before [DATE]. 4. A hearing on the [motion OR document] will be held at [TIME], [DATE], [LOCATION]. 5. You will not be provided with a separate notice or copy of any order issued by the Court following a decision on the [motion OR document], but can access any such order (without charge) at www.donlinrecano.com/sf. Dated: Click to enter a date [Counsel] FREDRIKSON & BYRON, P.A. 200 South Sixth Street, Suite 4000 Minneapolis, MN 55402-1425 (612) 492-7000 [PROPOSED] ATTORNEYS FOR THE DEBTOR

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VERIFICATION I, Matthew Whebbe, the Chairman and Chief Executive Officer of Tea Olive I, LLC (the “Debtor”), declare under penalty of perjury that the facts set forth in the preceding motion are true and correct according to the best of my knowledge, information, and belief, including based on information provided to me by other representatives of the Debtor and the Debtor’s professional advisors. Dated: January 10, 2021 Matthew Whebbe

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037 Chapter 11 Case Debtor. MEMORANDUM IN SUPPORT OF MOTION FOR ORDER (I) GRANTING EXPEDITED RELIEF AND (II) APPROVING THE DEBTOR’S PROPOSED NOTICE PROCEDURES FOR EMPLOYEES, ENROLLEES IN THE DEBTOR’S CUSTOMER PROGRAMS, AND GIFT CARD HOLDERS Tea Olive I, LLC d/b/a Stock+Field (the “Debtor”) submits this memorandum of law in support of the Motion for Order (I) Granting Expedited Relief and (II) Approving the Debtor’s Proposed Notice Procedures for Employees, Enrollees in the Debtor’s Customer Programs, and Gift Card Holders (the “Motion”), in accordance with Local Rule 9013-2(a). BACKGROUND The supporting facts are set forth in the Motion. All capitalized terms used herein and not otherwise defined shall have the meanings ascribed to them in the Motion. ANALYSIS I. THE DEBTOR’S REQUEST FOR EXPEDITED RELIEF SHOULD BE GRANTED. The Debtor requests expedited relief on the Motion. Bankruptcy Rule 9006(c) provides that the Court may reduce the notice period for a Motion “for cause shown.” Fed. R. Bankr. P. 9006(c). Cause exists here to reduce notice of the hearing on this Motion. The granting of this Motion on an expedited basis will allow the Debtor to use the Notice Procedures to supply notice of the commencement of this case (and later, other motions that are required to be served on the creditor matrix) while protecting individual information (including home addresses) and reaching

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individuals for whom the Debtor does not have any contact information. Given the nature of the information sought to be provided, including a proof of claim deadline that will quickly approach, cause exists to shorten the notice of the hearing on this Motion. II. THE COURT SHOULD APPROVE THE NOTICE PROCEDURES AND FIND THAT THEY PROVIDE GOOD, ADEQUATE, AND SUFFICIENT NOTICE. The Bankruptcy Code empowers courts to “issue any order, process, or judgment that is necessary or appropriate to carry out the provisions of [title 11 of the United States Code].” 11 U.S.C. § 105(a). Federal Rule of Bankruptcy Procedure 2002(m) states that “[t]he court may from time to time enter orders designating the matters in respect to which, the entity to whom, and the form and manner in which notices shall be sent except as otherwise provided by these rules.” Fed. R. Bankr. P. 2002(m). When the court “finds that notice by mail is impracticable” it may order notice by publication. Fed. R. Bankr. P. 2002(l). Furthermore, while certain Local Rules describe notice and service requirements for various types of motions and on different types of individuals or entities, this Court may suspend any Local Rules, including rules regarding notice and service, for “good cause.” Local Rule 9029-1(b). As further described in the Motion, good cause exists to approve the Notice Procedures, and to find that compliance with the Notice Procedures will result in good, adequate, and sufficient notice to the relevant individuals. The Notice Procedures set forth various methods of serving more than 1,000 current and former (from the past 12 months) employees; the enrollees in the Debtor’s Customer Programs, and the unknown holders of gift cards with a face dollar value of approximately $384,228. The Court is also empowered to approve the Notice Procedure under section 105(a) of the Bankruptcy Code because it is a process that will provide notice to the three categories of individuals while also furthering the policy of preserving valuable assets of the estate. With respect

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to the Employee Group, the Debtor’s proposed Notice Procedures ensure that the individuals’ privacy will be respected—by not including their home addresses on the publicly-available matrix or on certificates of service—but they will also receive notice of the commencement of the case and any other motion or document required to be served on the full matrix. In addition, the Debtor’s proposal to send a one-page Notice of Filing Motion or Other Document rather than a full copy of the relevant document will likely save thousands of dollars in copying and postage costs. At the same time, the Notice of Filing Motion or Other Document contains all the key information, and will direct the recipients to the Debtors’ case website, where they can access all filings at no cost. With respect to the Customer Program Group, the Debtor does not believe any notice is required, because individuals in that group are not creditors. Nevertheless, out of an abundance of caution, the Debtor proposes to provide notice of the case commencement (which will contain other key details, including information regarding the case website, where recipients can access information and copies of pleadings at no charge) by (a) e-mail or mail to Ag Plus members and (b) either an insert in the next credit card statement, or a postcard mailing to Stock+Field Mastercard holders. Again, the Debtor believes that this will be an effective, and also the most cost-effective, method of providing notice of the case filing to the Customer Program Group, particularly when combined with the additional electronic and social media notice proposals. With respect to the Gift Card Group, the Debtors propose to provide notice of this case by publishing the notice with a national newspaper publication and posting the notice on its website, in stores, in mass emails to the Debtor’s distribution lists, and on the Debtor’s social media platforms. Bankruptcy Rule 2002(m) allows the court to specify the manner in which notice may be delivered. While most of the Federal Rules provide for notice by mail, the provision for service

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by publication under Federal Rule 2002(l) indicates that the Federal Rules include the flexibility to deviate from mail service, and authorizes service by publication when mail service is impracticable. Here, mail service is impracticable because the identity and contact information for the Gift Card Holders is unknown. The Debtor has proposed publication notice through newspaper publication, its website, at physical stores, and electronically through its distribution lists and social media platforms. The physical in-store postings will reach the Debtors’ customers, many of whom may hold or have purchased and given away gift cards (in which case, they can alert the gift card holder). In addition, given the pervasiveness of technology and social media, the Debtor expects that these efforts will provide actual notice to most or many people in the Gift Card Group, and the other groups and parties. Furthermore, these procedures are cost-effective, which benefits the estate and all creditors by preserving estate resources. Accordingly, the proposed publication notice, with information directing readers to the case website, is appropriate. In sum, the Notice Procedures would ensure that the Employee Group, the Customer Program Group, and the Gift Card Group receive, to the best of the Debtor’s abilities, notice of the case and other events in the case, and the ability to participate, if they wish to do so. At the same time, approval of the Notice Procedures would provide certainty to the Debtor regarding the sufficiency of notice on the relevant individuals, and would preserve estate resources by focusing on notice methods that are expected to be not only effective at reaching the relevant individuals, but also cost-effective. CONCLUSION For the foregoing reasons, the Debtor respectfully requests that the Court enter an order granting the relief requested in the Motion.

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Dated: January 11, 2021 /e/ Steven R. Kinsella Clinton E. Cutler (#0158094) James C. Brand (#0387362) Steven R. Kinsella (#0392289) Samuel M. Andre (#0399669) FREDRIKSON & BYRON, P.A. 200 South Sixth Street, Suite 4000 Minneapolis, MN 55402-1425 (612) 492-7000 ccutler@fredlaw.com jbrand@fredlaw.com skinsella@fredlaw.com sandre@fredlaw.com PROPOSED ATTORNEYS FOR THE DEBTOR

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Case No.: 21-30037 Tea Olive I, LLC d/b/a Stock+Field, Chapter 11 Case Debtor. ORDER (I) GRANTING EXPEDITED RELIEF AND (II) APPROVING NOTICE PROCEDURES This case came before the court on the Motion for Order (I) Granting Expedited Relief; (II) Approving the Debtor’s Proposed Notice Procedures for Employees, Enrollees in the Debtor’s Customer Programs, and Gift Card Holders (the “Motion”) filed by the above-captioned debtor (the “Debtor”). Based on the Motion and the record, IT IS ORDERED: 1. The request for expedited relief is granted. 2. Pursuant to 28 U.S.C. § 105(a), Federal Rules of Bankruptcy Procedure 2002(l) and 2002(m), and Local Rule 9029-1(b), any applicable service and creditor matrix rules in the Federal Rules and Local Rules are modified with respect to the Employee Group, the Customer Program Group, and the Gift Card Group, all as defined in the Motion and provided for in this order. 3. The Debtor is authorized to use the following “Notice Procedures” for the Employee Group, the Customer Program Group, and the Gift Card Group, all as defined below: a. Employee Group. The Debtor is not required to list all of its current and former employees (the “Employee Group”) on the creditor matrix. The Debtor shall instead serve, by U.S. mail, on each individual in the Employee Group: (i) a copy of the notice of case commencement that will be issued by the office of the Clerk of Court; and (ii) a Notice

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of Filing Motion or Other Document, substantially in the form attached to the Motion as Exhibit A, for any motions or documents that the Debtor files that are required to be served on the full creditor matrix, where such notice will provide employees with the name of the motion or other document, the date by which any objection must be filed, the date of the hearing on the motion and the location of the hearing, and the address for the Debtors’ case information website maintained by the Debtor’s claims and noticing agent. The office of the Clerk of Court is not required to mail to the Employee Group any subsequent order on such a motion or other document; rather, as stated on the Notice of Filing Motion or Other Document, the order would be accessible on the Debtors’ case information website. If any envelope sent to individuals in the Employee Group are returned as undeliverable with no forwarding address, the Debtor is not required to include those individuals in any future mailings to the Employee Group. Within seven business days of each mailing described in this order being served, the Debtor will file a certificate of service that lists the first and last name of each individual served, with addresses redacted. The Debtor will maintain, but not file, a copy of the certificate of service with unredacted addresses. b. Customer Program Group. The Debtor is not required to list individuals that participate in the Debtor’s various customer programs, including its AG Plus program and its Stock+Field Mastercard Program, (the “Customer Program Group”) on the creditor matrix. The Debtor shall: (i) e-mail or mail by U.S. mail the notice of case commencement to all members of the Ag Plus program, depending on whether the Debtor has an e-mail address or physical address for such member; (ii) work with the administrator of the Stock+Field Mastercard Program to include an insert in the next monthly credit card statement mailed after January 9, 2021 (the “Filing Date”) notifying the cardholder of the

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bankruptcy filing; or (iii) if the credit card administrator will not or cannot include the insert in the credit card statement for no or a nominal cost, the Debtor will mail a postcard notice to the cardholders. The insert or postcard shall provide notice of the commencement of the case, and provide the address for the Debtor’s case information website maintained by the claims and noticing agent. If notice is provided via option (ii), the Debtor shall file a certificate of service attaching a copy of the insert, and in which the administrator certifies that the insert was added to the credit card statements, the date(s) the statements were sent, and the approximate number of statements sent with the insert. If notice is provided via option (iii), the Debtor shall file a certificate of service attaching a copy of the postcard, and indicating the date the postcards were sent, the approximate number sent, and the custodian of the records containing the names and addresses. c. Gift Card Group. The Debtor is not required to list individuals holding gift cards (the “Gift Card Group”) on the creditor matrix. The Debtor shall provide notice of the commencement of the case to the Gift Card Group (i) by publishing the notice once in a national newspaper, with the notice including the case number, claim filing deadline, and directions to accessing the case website hosted by the Debtor’s claims and noticing agent, (ii) by posting the notice on its website, (iii) physically posting the commencement in stores, (iv) sending notices through mass e-mails to the Debtor’s distribution lists, (v) posting notices on the Debtor’s social media platforms, and (vi) coordinating with the store closing consultant to post additional notices. 4. Unless a different notice procedure is specifically directed by subsequent court order for any specific motion, document, or other proceeding, compliance with the Notice Procedures shall constitute good, adequate, and sufficient notice on the Employee Group, the

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Customer Program Group, and the Gift Card Group of the commencement of this case and all motions, documents, or other proceedings in this order. 5. This order is effective immediately upon entry. Dated: ______________________________ William J. Fisher United States Bankruptcy Judge