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Full title: Certification of Counsel Regarding the Motion of Katherine Clelland for Relief from the Automatic Stay (related document(s)867) Filed by Katherine Clelland. (Attachments: # 1 Exhibit A- Proposed Agreed Order) (Busenkell, Michael) (Entered: 05/06/2021)

Document posted on May 5, 2021 in the bankruptcy, 2 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

On April 20, 2021, Katherine Clelland (“Movant”) filed her Motion for Relief from the Automatic Stay Pursuant to Section 362(d) of the Bankruptcy Code [D.I. 867]Prior to the hearing, the Debtors and counsel for the Movant agreed to the terms set forth in the stipulation and proposed order attached hereto as Exhibit A that resolves the Motion. 1Due to the large number of debtor entities in these chapter 11 cases, for which joint administration has been requested, a complete list of the debtor entities and the last four digits of their federal tax identification numbers is not provided herein.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. Based on the foregoing, the undersigned respectfully submits that the Court may enter the proposed order since no other responses were received and since the form of order is consensual as to only the interested parties who responded to the Motion.

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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) (Jointly Administered) Debtors. Related to Docket No. 867 CERTIFICATION OF COUNSEL WITH RESPECT TO MOTION OF KATHERINE CLELLAND FOR RELIEF FROM AUTOMATIC STAY I, Michael Busenkell, hereby certify the following: 1. On April 20, 2021, Katherine Clelland (“Movant”) filed her Motion for Relief from the Automatic Stay Pursuant to Section 362(d) of the Bankruptcy Code [D.I. 867] (the “Motion”) with the United States Bankruptcy Court for the District of Delaware (the “Court”). 2. As set forth in the Motion, the objection deadline was May 4, 2021 at 4:00 p.m. (ET), and a hearing was scheduled for May 25, 2021. 3. Prior to the hearing, the Debtors and counsel for the Movant agreed to the terms set forth in the stipulation and proposed order attached hereto as Exhibit A that resolves the 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, for which joint administration has been requested, 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 proposed 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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4. Based on the foregoing, the undersigned respectfully submits that the Court may enter the proposed order since no other responses were received and since the form of order is consensual as to only the interested parties who responded to the Motion. WHEREFORE, the undersigned respectfully submits that the Court may enter the proposed order attached hereto as Exhibit A without further notice or a hearing. Date: May 6, 2021 Wilmington, Delaware Respectfully submitted, GELLERT SCALI BUSENKELL & BROWN, LLC /s/ Michael Busenkell Michael Busenkell (DE 3933) 1201 N. Orange Street, Suite 300 Wilmington, DE 19801 Telephone: (302) 425-5812 Facsimile: (302) 425-5814 mbusenkell@gsbblaw.com Attorneys for Katherine Clelland

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