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Full title: Certification of Counsel Regarding Motion of Juanita Aguilar for Relief from Automatic Stay (related document(s)576) Filed by Juanita Aguilar. (Attachments: # 1 Exhibit A (Proposed Agreed Order) # 2 Exhibit B (Redline)) (Mangan, Kevin) (Entered: 01/19/2021)

Document posted on Jan 18, 2021 in the bankruptcy, 2 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Pursuant to the notice appended to the Motion, objections or responses to the Motion were due on or before January 13, 2021 at 4:00 p.m. Prior to the objection deadline, counsel for the above-captioned debtors and debtors in possession (collectively, “Debtors”) responded informally to the Motion.To resolve the Debtors’ informal response, Movant, Debtors, and the Official Committee of Unsecured Creditors have agreed to the entry of the proposed agreed order attached hereto as Exhibit A approving the Motion (the “Agreed Order”).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.The undersigned further certifies that the Court’s docket in these cases reflects that no answer, objection, or other responsive pleading to the Motion has been filed.

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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., Case No. 20-12841 (MFW) Debtors.1 (Jointly Administered) Related Docket No.: 576 Hearing Date: January 20, 2021 at 10:30 a.m. (ET) CERTIFICATION OF COUNSEL REGARDING MOTION OF JUANITA AGUILAR FOR RELIEF FROM AUTOMATIC STAY The undersigned counsel to Juanita Aguilar (“Movant”) hereby certifies as follows: 1. On December 30, 2020, Movant filed the Motion of Juanita Aguilar for Relief from Automatic Stay [Docket No. 576] (the “Motion”) with the United States Bankruptcy Court for the District of Delaware (the “Court”). Pursuant to the notice appended to the Motion, objections or responses to the Motion were due on or before January 13, 2021 at 4:00 p.m. A hearing on the Motion is currently scheduled for January 20, 2021 at 10:30 a.m. 2. Prior to the objection deadline, counsel for the above-captioned debtors and debtors in possession (collectively, “Debtors”) responded informally to the Motion. To resolve the Debtors’ informal response, Movant, Debtors, and the Official Committee of Unsecured Creditors have agreed to the entry of the proposed agreed order attached hereto as Exhibit A approving the Motion (the “Agreed Order”). For the convenience of the Court and parties in interest, attached 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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hereto as Exhibit B is a redline reflecting the changes between the proposed form of order filed with the Motion and the Agreed Order. 3. Except as set forth herein, no other informal or formal response to the Motion has been received. The undersigned further certifies that the Court’s docket in these cases reflects that no answer, objection, or other responsive pleading to the Motion has been filed. 4. Accordingly, the undersigned counsel to Movant respectfully requests that the Agreed Order be entered at the earliest convenience of the Court without further notice or a hearing. Dated: January 19, 2021 WOMBLE BOND DICKINSON (US) LLP Wilmington, Delaware /s/ Kevin J. Mangan Kevin J. Mangan (DE No. 3810) 1313 North Market Street, Suite 1200 Wilmington, Delaware 19801 (302) 252-4320 telephone (302) 252-4330 facsimile kevin.mangan@wbd-us.com -and- IURILLO LAW GROUP, P.A. Camille J. Iurillo (admitted pro hac vice) Fla. Bar No. 902225 Kevin L. Hing Fla. Bar No. 0071976 5628 Central Avenue St. Petersburg, Florida 33707 (727) 895-8050 telephone (727) 895-8057 facsimile ciurillo@iurillolaw.com khing@iurillolaw.com Attorneys for Juanita Aguilar