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Full title: Motion to Shorten Notice Period for Debtors' Motion for Entry of an Order Authorizing the Debtors to Make Payments to Certain Employees Under the Debtors' Pre-Petition Bonus Program (related document(s)689) Filed by YouFit Health Clubs, LLC. (Attachments: # 1 Exhibit A - Proposed Order) (Meloro, Dennis) (Entered: 01/27/2021)

Document posted on Jan 26, 2021 in the bankruptcy, 5 pages and 0 tables.

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By this motion (the “Motion to Shorten”), 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 Authorizing the Debtors to Make Payments to Certain Employees Under the Debtors’ Prepetition Bonus Program (the “Bonus Payment 1 The last four digits of YouFit Health Clubs, LLC’s tax identification number are 6607.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.By this Motion, the Debtors respectfully request that the Court enter the Proposed Order (a) scheduling a hearing (the “Hearing”) on the Bonus Payment Motion for February 2, 2021, at 10:30 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 February 1, 2021, at 12:00 p.m. (prevailing Eastern Time).Contemporaneously with the filing of this Motion to Shorten, the Debtors will serve this Motion to Shorten, together with the Bonus Payment Motion, on the following parties, or their counsel, if known, by facsimile, electronic mail, hand delivery, overnight mail, or express mail: (a) the U.S. Trustee; (b) Lenders’ Counsel; (c) counsel to the Committee; and (d) 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 AUTHORIZING THE DEBTORS TO MAKE PAYMENTS TO CERTAIN EMPLOYEES UNDER THE DEBTORS’ PRE-PETITION BONUS PROGRAM By this motion (the “Motion to Shorten”), 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 Authorizing the Debtors to Make Payments to Certain Employees Under the Debtors’ Prepetition Bonus Program (the “Bonus Payment 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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Motion”)2 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 Bonus Payment Motion seeking the entry of an order authorizing the Debtors to pay certain of their employees annual or quarterly bonuses related to the 2020 fiscal year or the fourth quarter of the 2020 fiscal year. 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 Bonus Payment Motion for February 2, 2021, at 10:30 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 February 1, 2021, at 12:00 p.m. (prevailing Eastern Time). 2 Capitalized terms used but not otherwise defined herein shall have the meanings set forth in the Bonus Payment Motion.

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BASIS FOR RELIEF A. THE BANKRUPTCY RULES AND LOCAL RULES ALLOW FOR SHORTENED NOTICE OF THE BONUS PAYMENT MOTION 5. Bankruptcy Rules 9006(d) and 9013 provide that moving papers must be served at least seven (7) days before a hearing date. See Fed R. Bankr. P. 9006(d), 9013. In addition, 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 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 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’ Performance Under the Stalking Horse Purchase Agreement, (III) Approving the Assumption and Assignment of Certain of the Debtors’ Executory Contracts and Unexpired Leases Related

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Thereto, and (IV) Granting Related Relief [Docket No. 564]. Although the Debtors anticipate that it will close in the near future, the sale will not close before January 31, 2021, which is when the bonus payments that are the subject of the Bonus Payment Motion are typically made. The Debtors’ employees rely on these bonus payments as part of their ordinary course compensation. Thus, to maintain employee morale, the Debtors believe it is critical to be able to make such payments as soon after January 31 as possible. Moreover, the Debtors’ lenders have agreed to fund the bonus payments out of the DIP budget. 8. Based on the foregoing, the Debtors respectfully submit that expedited consideration of the Bonus Payment Motion on February 2, 2021, as requested herein, is justified under the circumstances of these chapter 11 cases. COMPLIANCE WITH LOCAL RULE 9006-1(e) 9. Prior to filing 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 official committee of unsecured creditors appointed in these cases (the “Committee”), and counsel for the Debtors’ prepetition and postpetition lenders and administrative and collateral agents (collectively, “Lenders’ Counsel”) with respect to the relief sought in this Motion to Shorten and the Bonus Payment Motion. The U.S. Trustee, counsel for the Committee, and Lenders’ Counsel have consented to the relief sought in this Motion to Shorten. NOTICE 10. Contemporaneously with the filing of this Motion to Shorten, the Debtors will serve this Motion to Shorten, together with the Bonus Payment Motion, on the following parties, or their counsel, if known, by facsimile, electronic mail, hand delivery, overnight mail, or express mail: (a) the U.S. Trustee; (b) Lenders’ Counsel; (c) counsel to the Committee; and

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(d) 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. CONCLUSION WHEREFORE, the Debtors respectfully request that the Court (i) enter the Proposed Order (a) scheduling the Hearing on the Bonus Payment Motion for February 2, 2021, at 10:30 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 February 1, 2021, at 12:00 p.m. (prevailing Eastern Time); and (ii) grant such other and further relief as the Court may deem just and appropriate GREENBERG TRAURIG, LLP Dated: January 27, 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

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