HTML Document View

Full title: Certification of Counsel Requesting Entry of Order (A) Dismissing Chapter 11 Case, and (B) Granting Related Relief (related document(s)929) Filed by YouFit Health Clubs, LLC. (Attachments: # 1 Exhibit A # 2 Exhibit B) (Meloro, Dennis) (Entered: 06/23/2021)

Document posted on Jun 22, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

On June 8, 2021, the Maricopa County Treasurer filed the Maricopa County Treasurer’s Response and Objection to Motion of the Debtors for Entry of an Order (A) Dismissing the Chapter 11 Cases, and (B)On June 17, 2021, Fish Window Cleaning of Tallahassee filed the Objection of Fish Window Cleaning of Tallahassee to Motion of the Debtors for Entry of an Order (A) Dismissing the Chapter 11 Cases, and (B)On June 22, 2021, the Maricopa County Treasurer filed the Notice of Withdrawal of Maricopa County Treasurer’s Response and Objection to Motion of the Debtors for Entry of an Order (A) Dismissing the Chapter 11 Cases, and (B)On June 23, 2021, the Court held a hearing (the “Hearing”) on the Motion during which the Court overruled the Fish Window Cleaning Objection and indicated it would grant the Motion subject to the submission of a revised proposed order with a revised schedule for the submission of final fee applications by professionals in these chapter 11 cases.Attached hereto as Exhibit A is a proposed order granting the Motion, which proposed order contains the revisions discussed on the record at the Hearing.

List of Tables

Document Contents

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) CERTIFICATION OF COUNSEL REQUESTING ENTRY OF ORDER (A) DISMISSING CHAPTER 11 CASE, AND (B) GRANTING RELATED RELIEF The undersigned counsel to the above-captioned debtors and debtors in possession (the “Debtors”) hereby certifies that: 1. On May 27, 2021, the Debtors filed the Motion of the Debtors for Entry of an Order (A) Dismissing the Chapter 11 Cases, and (B) Granting Related Relief [Docket No. 929] (the “Motion”) and the Motion to Limit Notice [Docket No. 930] (the “Motion to Limit Notice”) with the Bankruptcy Court for the United States Bankruptcy Court for the District of Delaware (the “Court”). 2. On June 3, 2021, the Court entered the Order Authorizing the Debtors to Limit Notice [Docket No. 933] (the “Order Limiting Notice”) 3. On June 8, 2021, the Maricopa County Treasurer filed the Maricopa County Treasurer’s Response and Objection to Motion of the Debtors for Entry of an Order (A) Dismissing the Chapter 11 Cases, and (B) Granting Related Relief [Docket No. 940] (the “Maricopa County Objection”). 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.

1

4. On June 17, 2021, Fish Window Cleaning of Tallahassee filed the Objection of Fish Window Cleaning of Tallahassee to Motion of the Debtors for Entry of an Order (A) Dismissing the Chapter 11 Cases, and (B) Granting Related Relief [Docket No. 945] (the “Fish Window Cleaning Objection” and together with the Maricopa County Objection, the “Objections”). 5. On June 18, 2021, the Debtors filed the Debtors’ Omnibus Response in Support of Motion to Dismiss [Docket No. 947] in response to the Objections. 6. On June 22, 2021, the Maricopa County Treasurer filed the Notice of Withdrawal of Maricopa County Treasurer’s Response and Objection to Motion of the Debtors for Entry of an Order (A) Dismissing the Chapter 11 Cases, and (B) Granting Related Relief [Docket No. 952], thereby withdrawing the Maricopa County Objection. 7. On June 23, 2021, the Court held a hearing (the “Hearing”) on the Motion during which the Court overruled the Fish Window Cleaning Objection and indicated it would grant the Motion subject to the submission of a revised proposed order with a revised schedule for the submission of final fee applications by professionals in these chapter 11 cases. 8. Attached hereto as Exhibit A is a proposed order granting the Motion, which proposed order contains the revisions discussed on the record at the Hearing. 9. Attached hereto as Exhibit B is a blackline of the proposed order attached hereto as Exhibit A against the original proposed order filed with the Motion on May 27, 2021.

2

Dated: June 23, 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) 661-7395 Facsimile: (302) 661-7165 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 to the Debtors and Debtors in Possession

3