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Full title: Certificate of No Objection Regarding Debtors' Motion for Entry of an Order Enlarging the Time Within Which to File Notices of Removal (related document(s)601) Filed by YouFit Health Clubs, LLC. (Meloro, Dennis) (Entered: 01/14/2021)

Document posted on Jan 13, 2021 in the bankruptcy, 2 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Docket No. 601 CERTIFICATE OF NO OBJECTION REGARDING DEBTORS’ MOTION FOR ENTRY OF AN ORDER ENLARGING THE TIME WITHIN WHICH TO FILE NOTICES OF REMOVAL On January 5, 2021, the Debtors filed the Debtors’ Motion for Entry of an Order Enlarging the Time Within Which to File Notices of Removal [Docket No. 601] (the “Motion”) with the United States Bankruptcy Court for the District of Delaware (the “Court”).Pursuant to the Notice of Motion, objections were due by 4:00 p.m. (prevailing Eastern Time) on January 13, 2021. The Debtors therefore respectfully request that the Court enter the proposed form of order attached to the Motion at its earliest convenience.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.

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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) Ref. Docket No. 601 CERTIFICATE OF NO OBJECTION REGARDING DEBTORS’ MOTION FOR ENTRY OF AN ORDER ENLARGING THE TIME WITHIN WHICH TO FILE NOTICES OF REMOVAL The undersigned counsel to the above-captioned debtors and debtors in possession (collectively, the “Debtors”) hereby certifies that: 1. On January 5, 2021, the Debtors filed the Debtors’ Motion for Entry of an Order Enlarging the Time Within Which to File Notices of Removal [Docket No. 601] (the “Motion”) with the United States Bankruptcy Court for the District of Delaware (the “Court”). 2. Pursuant to the Notice of Motion, objections were due by 4:00 p.m. (prevailing Eastern Time) on January 13, 2021. As of the date hereof, the undersigned counsel has not received any answers, objections or other responsive pleadings to the Motion. 3. The Debtors therefore respectfully request that the Court enter the proposed form of order attached to the Motion at its earliest convenience. 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.

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Dated: January 14, 2021 Respectfully submitted, Wilmington, Delaware GREENBERG TRAURIG, LLP /s/ Dennis A. Meloro Dennis A. Meloro (DE Bar No. 4435) The Nemours Building 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) 456-8400 Facsimile: (312) 456-8435 Email: petermann@gtlaw.com howee@gtlaw.com ballenn@gtlaw.com Counsel for the Debtors and Debtors in Possession