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Full title: Motion to Shorten Debtors' Motion to Shorten Notice Period for Debtors' Motion for Entry of an Order (I) Fixing Deadlines for Filing Proofs of Claim and (II) Approving the Form and Manner of Notice Thereof (related document(s)622) Filed by YouFit Health Clubs, LLC. (Attachments: # 1 Exhibit A) (Meloro, Dennis) (Entered: 01/11/2021)

Document posted on Jan 10, 2021 in the bankruptcy, 6 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

By this motion (the “Motion to Shorten”),2 the above-captioned debtors and debtors in possession (collectively, the “Debtors”) request entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), pursuant to section 105(a) of title 11 of the United States Code (the “Bankruptcy Code”), Rules 2002 and 9006 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 9006-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), scheduling a hearing and shortening the notice period with respect to the Debtors’ Motion for Entry of an Order (I) Fixing Deadlines for Filing Proofs of Claim and (II) Approving the Form and Manner of Notice Thereof (the “Bar Date Motion”)By this Motion, the Debtors respectfully request that the Court enter the Proposed Order (a) scheduling a hearing (the “Hearing”) on the Bar Date Motion for January 20, 2021, at 9:30 a.m. (prevailing Eastern Time), and (b) shortening the notice period for the Hearing, with responses or objections, if any, to be filed on or before January 19, 2021, at 12:00 p.m. (prevailing Eastern Time).On Friday, January 8, 2021 and on the date of the filing of this Motion to Shorten, the Debtors conferred with the Office of the United States Trustee for the District of Delaware (the “U.S. Trustee”), counsel for the Committee, and counsel for the Debtors’ prepetition and postpetition lenders and administrative and collateral agent with respect to the relief sought in this Motion to Shorten and the Bar Date Motion.Contemporaneously with the filing of this Motion to Shorten, the Debtors will serve this Motion to Shorten, together with the Bar Date Motion, on the following parties, or their counsel, if known, by facsimile, electronic mail, hand delivery, overnight mail, or express mail: Notice of this Motion has been given to the following parties or, in lieu thereof, to their counsel, if known, by facsimile, electronic mail, hand delivery, overnight mail, or express mail: (a) the Office of the United States Trustee for the District of Delaware; (b) the Debtors’ prepetition and postpetition lenders and administrative and collateral agent; (c) counsel to the Committee; (d) parties that filed objections to the DIP Financing Motion; and (e) any party that has requested notice pursuant to Bankruptcy Rule 2002.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re Chapter 11 YOUFIT HEALTH CLUBS, LLC, et al.,1 Case No. 20-12841 (MFW) Debtors. (Jointly Administered) DEBTORS’ MOTION TO SHORTEN NOTICE PERIOD FOR DEBTORS’ MOTION FOR ENTRY OF AN ORDER (I) FIXING DEADLINES FOR FILING PROOFS OF CLAIM AND (II) APPROVING THE FORM AND MANNER OF NOTICE THEREOF By this motion (the “Motion to Shorten”),2 the above-captioned debtors and debtors in possession (collectively, the “Debtors”) request entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), pursuant to section 105(a) of title 11 of the United States Code (the “Bankruptcy Code”), Rules 2002 and 9006 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 9006-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), scheduling a hearing and shortening the notice period with respect to the Debtors’ Motion for Entry of an Order (I) Fixing Deadlines for Filing Proofs of Claim and (II) Approving the Form and Manner of Notice Thereof (the “Bar Date Motion”) 1 The last four digits of YouFit Health Clubs, LLC’s tax identification number are 6607. Due to the large number of debtor entities in these chapter 11 cases, a complete list of the debtor entities and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the website of the claims and noticing agent at www.donlinrecano.com/yfhc. The mailing address for the debtor entities for purposes of these chapter 11 cases is: 1350 E. Newport Center Dr., Suite 110, Deerfield Beach, FL 33442. 2 Capitalized terms used and not otherwise defined herein have the meanings ascribed to them in the Bar Date Motion (as defined herein).

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filed and served contemporaneously herewith. In support of this Motion to Shorten, the Debtors respectfully state as follows: JURISDICTION AND VENUE 1. The Court has jurisdiction to consider 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 is a core proceeding pursuant to 28 U.S.C. § 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409. 2. Pursuant to Local Rule 9013-1(f), the Debtors consent to the entry of a final order by the Court in connection with this Motion to Shorten to the extent 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. BACKGROUND 3. Contemporaneously herewith, the Debtors have filed the Bar Date Motion seeking the entry of an order (a) fixing the General Bar Date as February 22, 2021, (b) fixing the Government Bar Date as May 8, 2021, (c) establishing general procedures with respect to the Bar Dates, and (d) approving the form and manner of notice with respect to the Bar Dates. RELIEF REQUESTED 4. By this Motion, the Debtors respectfully request that the Court enter the Proposed Order (a) scheduling a hearing (the “Hearing”) on the Bar Date Motion for January 20, 2021, at 9:30 a.m. (prevailing Eastern Time), and (b) shortening the notice period for the Hearing, with responses or objections, if any, to be filed on or before January 19, 2021, at 12:00 p.m. (prevailing Eastern Time).

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BASIS FOR RELIEF A. THE BANKRUPTCY RULES AND LOCAL RULES ALLOW FOR SHORTENED NOTICE OF THE BAR DATE MOTION 5. Bankruptcy Rule 3003 provides that “[t]he court shall fix . . . the time within which proofs of claim or interest may be filed. . . .” Fed. R. Bankr. P. 3003(c). Bankruptcy Rule 9006(d) and 9013 provide that moving papers must be served out on at least seven (7) days before a hearing date, see Fed R. Bankr. P. 9006(d), 9013, and Local Rule 9006-1(c)(i) provides that “all motion papers shall be filed and served . . . at least fourteen (14) days prior to the hearing date.” Del. Bankr. L.R. 9006-1(c)(i). Further, as a default, Local Rule 9006-1(c)(ii) provides, “the deadline for objection(s) shall be no later than seven (7) days before the hearing date.” Del. Bankr. L.R. 9006-1(c)(ii). 6. Both the Bankruptcy Rules and Local Rules allow a court to deviate from the time periods required by the Bankruptcy Rules and Local Rules. Bankruptcy Rule 9006(c)(1) allows a court to shorten time periods set by the Bankruptcy Rules “for cause shown” in the court’s discretion. Fed. R. Bankr. P. 9006(c)(1). Similarly, Local Rule 9006-1(e) allows a court to schedule matters on less notice than that required by the Bankruptcy Rules or the Local Rules upon a motion specifying the “exigencies justifying shortened notice.” Del. Bankr. L.R. 9006-1(e). As discussed below, the Debtors respectfully submit that cause exists here and shortened notice is appropriate under the circumstances of these chapter 11 cases. B. THE CIRCUMSTANCES OF THESE CHAPTER 11 CASES SUPPORT THE RELIEF REQUESTED, WHICH WILL NOT PREJUDICE PARTIES IN INTEREST 7. The Court recently approved the sale of substantially all of the Debtors’ assets pursuant to the Order (I) Authorizing the Sale of All of the Debtors’ Assets Free and Clear of Liens, Claims, Encumbrances, and Other Interests, (II) Authorizing and Approving the Debtors’

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Performance Under the Stalking Horse Purchase Agreement, (III) Approving the Assumption and Assignment of Certain of the Debtors’ Executory Contracts and Unexpired Leases Related Thereto, and (IV) Granting Related Relief [Docket No. 564]. In connection therewith, the Debtors, the Committee, and the Debtors’ lenders resolved the Committee’s sale objection pursuant to the terms set forth in the sale order and discussed on the record at the sale hearing. Certain of the terms of that settlement will be implemented through a plan of liquidation. Accordingly, the Debtors intend to move the plan process forward as quickly and efficiently as possible to avoid unnecessary costs in these cases. Fixing a bar date as soon as possible is a key step in that process. The Debtors believe that a reduction of the notice period for the Bar Date Motion, so that the Bar Date Motion may be heard on the omnibus hearing date in January, is necessary to keep the Debtors’ plan process moving on an efficient timeline. 8. The Debtors do not believe that shortening the notice period as provided for herein will prejudice any party in interest. The Debtors are not seeking an accelerated bar date or any other accelerated substantive relief in the Bar Date Motion. 9. Based on the foregoing, the Debtors respectfully submit that expedited consideration of the Bar Date Motion on January 20, 2021, as requested herein, is justified under the circumstances of these chapter 11 cases. COMPLIANCE WITH LOCAL RULE 9006-1(e) 10. On Friday, January 8, 2021 and on the date of the filing of this Motion to Shorten, the Debtors conferred with the Office of the United States Trustee for the District of Delaware (the “U.S. Trustee”), counsel for the Committee, and counsel for the Debtors’ prepetition and postpetition lenders and administrative and collateral agent with respect to the relief sought in this Motion to Shorten and the Bar Date Motion. Counsel for the Committee and counsel for the

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lenders have consented to the relief sought in this Motion to Shorten. Given the timing of the filing of this Motion to Shorten, the Debtors have not yet received a response from the U.S. Trustee. NOTICE 11. Contemporaneously with the filing of this Motion to Shorten, the Debtors will serve this Motion to Shorten, together with the Bar Date Motion, on the following parties, or their counsel, if known, by facsimile, electronic mail, hand delivery, overnight mail, or express mail: Notice of this Motion has been given to the following parties or, in lieu thereof, to their counsel, if known, by facsimile, electronic mail, hand delivery, overnight mail, or express mail: (a) the Office of the United States Trustee for the District of Delaware; (b) the Debtors’ prepetition and postpetition lenders and administrative and collateral agent; (c) counsel to the Committee; (d) parties that filed objections to the DIP Financing Motion; and (e) any party that has requested notice pursuant to Bankruptcy Rule 2002. The Debtors submit that, in light of the nature of the relief requested, no other or further notice need be given. [Remainder of This Page Intentionally Left Blank]]

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CONCLUSION WHEREFORE, the Debtors respectfully request that the Court (i) enter the Proposed Order (a) scheduling the Hearing on the Bar Date Motion for January 20, 2021, at 9:30 a.m. (prevailing Eastern Time), and (b) shortening the notice period for the Hearing, such that objections, if any, may be made on or before January 19, 2021, at 12:00 p.m.; and (ii) grant such other and further relief as the Court may deem just and appropriate GREENBERG TRAURIG, LLP Dated: January 11, 2021 /s/ Dennis A. Meloro Dennis A. Meloro (DE Bar No. 4435) 1007 North Orange Street, Suite 1200 Wilmington, Delaware 19801 Telephone: (302) 661-7000 Facsimile (302) 661-7360 Email: melorod@gtlaw.com -and- Nancy A. Peterman (admitted pro hac vice) Eric Howe (admitted pro hac vice) Nicholas E. Ballen (admitted pro hac vice) 77 West Wacker Dr., Suite 3100 Chicago, Illinois 60601 Telephone: (312) 456-8410 Facsimile: (312) 456-8435 Email: petermann@gtlaw.com howee@gtlaw.com ballenn@gtlaw.com Counsel for the Debtors and Debtors in Possession