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Full title: Motion to Limit Notice (related document(s)929) Filed by YouFit Health Clubs, LLC. Hearing scheduled for 6/23/2021 at 10:30 AM at US Bankruptcy Court, 824 Market St., 5th Fl., Courtroom #4, Wilmington, Delaware. Objections due by 6/16/2021. (Attachments: # 1 Exhibit A - Proposed Order # 2 Notice) (Meloro, Dennis) (Entered: 05/27/2021)

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

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The above-captioned debtors and debtors-in-possession (the “Debtors”) hereby move this Court (the “Motion to Limit”) for entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), providing that notice of the Motion of the Debtors for Entry of an Order (A) Dismissing the Chapter 11 Cases, and (B)Granting Related Relief (the “Motion to Dismiss”) may be limited to (i) serving the Motion to Dismiss upon (a) the Office of the United States Trustee for the District of Delaware (the “U.S. Trustee”), (b) counsel to the Committee, and (c) counsel to the Debtors’ prepetition and postpetition lenders and administrative and collateral agent (collectively, the “Lenders”) and YF FC Acquisition, LLC (the “Buyer”), and (d) those parties who have requested notice pursuant to Rule 2002 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and (ii) serving a notice of the Motion to Dismiss, substantially in the form annexed as Exhibit 1 to the Proposed Order (the “Notice of Motion”), on all creditors.The United States Bankruptcy Court for the District of Delaware (the “Court”) has jurisdiction over this Motion 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.By this Motion, the Debtors request entry of an order, in the form of the Proposed Order, providing that notice of the Motion to Dismiss may be limited to (i) serving the Motion to Dismiss upon (a) the U.S. Trustee, (b) counsel to the Committee, and (c) counsel to the Lenders and the Buyer, and (d) those parties who have requested notice pursuant to In light of the limited resources of the Debtors’ estates (which itself is one of the bases for the Motion to Dismiss), the Debtors believe that the benefit to the estates in limiting notice outweighs any potential prejudice to creditors who receive the Notice of 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) Debtors. (Jointly Administered) Obj. Deadline: June 16, 2021 at 4:00 p.m. (ET) Hearing Date: June 23, 2021 at 10:30 a.m. (ET) MOTION TO LIMIT NOTICE The above-captioned debtors and debtors-in-possession (the “Debtors”) hereby move this Court (the “Motion to Limit”) for entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), providing that notice of the Motion of the Debtors for Entry of an Order (A) Dismissing the Chapter 11 Cases, and (B) Granting Related Relief (the “Motion to Dismiss”) may be limited to (i) serving the Motion to Dismiss upon (a) the Office of the United States Trustee for the District of Delaware (the “U.S. Trustee”), (b) counsel to the Committee, and (c) counsel to the Debtors’ prepetition and postpetition lenders and administrative and collateral agent (collectively, the “Lenders”) and YF FC Acquisition, LLC (the “Buyer”), and (d) those parties who have requested notice pursuant to Rule 2002 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and (ii) serving a notice of the Motion to Dismiss, substantially in the form annexed as Exhibit 1 to the Proposed Order (the “Notice of Motion”), on all creditors. In support of the Motion to Limit, the Debtors respectfully state as follows: 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 the 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 the Chapter 11 Cases is: 1350 E. Newport Center Dr., Suite 110, Deerfield Beach, FL 33442.

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Jurisdiction, Venue and Statutory Predicates 1. The United States Bankruptcy Court for the District of Delaware (the “Court”) has jurisdiction over this Motion 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 matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Under Rule 9013-1(f) of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), the Debtors consent to entry of a final order under Article III of the United States Constitution. Venue is proper in this district pursuant to 28 U.S.C. §§ 1408 and 1409. 2. The statutory predicate for the relief sought herein is Bankruptcy Rule 2002(a) and Local Rule 2002-1. Background 3. On November 9, 2020 (the “Petition Date”), the Debtors each filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code in this Court. On November 18, 2020, the United States Trustee appointed an official committee of unsecured creditors (the “Committee”) in the Chapter 11 Cases pursuant to section 1102 of the Bankruptcy Code. No trustee or examiner has been appointed in the Chapter 11 Cases. The Debtors have continued in possession of their properties and operated and managed their business as debtors in possession under sections 1107(a) and 1108 of the Bankruptcy Code through February 18, 2021, the date of the closing of the sale of all or substantially all of the Debtors’ assets to the Buyer. 4. On May 27, 2021, the Debtors filed the Motion to Dismiss. Relief Requested 5. By this Motion, the Debtors request entry of an order, in the form of the Proposed Order, providing that notice of the Motion to Dismiss may be limited to (i) serving the Motion to

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Dismiss upon (a) the U.S. Trustee, (b) counsel to the Committee, and (c) counsel to the Lenders and the Buyer, and (d) those parties who have requested notice pursuant to Bankruptcy Rule 2002, and (ii) serving a notice of the Motion to Dismiss, substantially in the form of the Notice of Motion, on all creditors. Basis for Relief Requested 6. Bankruptcy Rule 2002(a)(4) and Local Rule 2002-1(b) provide for notice of the hearing on the Motion to Dismiss on all creditors and indenture trustees by mail at least 21 days before the hearing. See Fed. R. Bankr. P. 2002(a)(4); Del. Bankr. L.R. 2002-1(b). Bankruptcy Rules 2002(m) and 9007 provide that the Court has general authority to regulate standards for notices, including, without limitation, the form and manner of notices, except as otherwise provided by the Bankruptcy Rules. See Fed. R. Bankr. P. 2002(m), 9007. 7. The Debtors currently have approximately 12,645 parties listed on the creditors’ matrix. Serving the entire Motion to the Dismiss by mail on all creditors would require printing and mailing approximately 30 pages of materials to at least 12,645 addresses at significant expense to the estates. The Debtors’ claim agent estimates that doing so would cost at least $52,000. If the Debtors instead serve the two-page Notice of Motion on all creditors, the cost will be approximately $12,000, which is a savings of approximately $40,000. 8. The Debtors believe that serving only the Notice of Motion on the creditor matrix will be sufficient to give creditors an opportunity to be heard with respect to the relief requested in the Motion to Dismiss. Bankruptcy Rule 2002(a)(4) requires only notice of the hearing on a motion to dismiss, which the Notice of Motion will provide. Moreover, the Notice of Motion will provide creditors with the opportunity to obtain copies of the Motion to Dismiss in its entirety, including instructions on how to obtain copies for free on the website maintained by the

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Debtors claims agent. In light of the limited resources of the Debtors’ estates (which itself is one of the bases for the Motion to Dismiss), the Debtors believe that the benefit to the estates in limiting notice outweighs any potential prejudice to creditors who receive the Notice of Motion. Notice 9. Notice of this Motion has been given to the following parties or, in lieu thereof, to their counsel, if known: (a) the U.S. Trustee; (b) counsel to the Lenders and the Buyer; (c) counsel to the Committee; and (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. No Prior Request 10. No prior request for the relief sought in this Motion has been made to this or any other court. Conclusion WHEREFORE, for the reasons set forth herein, the Debtors respectfully requests that this Court approve the relief requested in this Motion and grant such other and further relief as is just and proper.

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Dated: May 27, 2021 GREENBERG TRAURIG, LLP /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) 456-8400 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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