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Full title: Certification of Counsel Regarding Motion to Lift Stay of Alexis A. Brown (related document(s)[991]) Filed by Advantage Holdco, Inc.. (Attachments: # (1) Exhibit A) (Roth-Moore, Andrew)

Document posted on Nov 8, 2021 in the bankruptcy, 2 pages and 0 tables.

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IN RE ADVANTAGE HOLDCO, INC., et al.(the “Motion”), which seeks an order lifting the automatic stay to permit insurer Scottsdale Insurance Company (the “Insurer”) to distribute funds to the Movant under a Debtor owned commercial liability insurance policy in settlement of any and all of the Movant’s claims.The Movant subsequently submitted to Debtors’ counsel the draft proposed order attached hereto as Exhibit A (the “Proposed Order”) granting the relief sought in the Motion.Further, the Movant has advised Debtors’ counsel that counsel for the Insurer also does not oppose its entry.WHEREFORE, at the Movant’s request, counsel for the Debtors submits the Proposed Order for the Court’s consideration.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE Chapter 11 In re Case Nos. 20-11259 (CTG) IN RE ADVANTAGE HOLDCO, INC., et al., Jointly Administered Debtors. Re: Docket No. 991 CERTIFICATION OF COUNSEL REGARDING MOTION TO LIFT STAY OF ALEXIS A. BROWN The undersigned, counsel to the above-captioned debtors and debtors in possession (collectively, the “Debtors”), hereby certifies as follows: 1. On October 21, 2021, Alexis A. Brown (“Movant”), acting pro se, filed the Motion to Lift Stay [Docket No. 991] (the “Motion”), which seeks an order lifting the automatic stay to permit insurer Scottsdale Insurance Company (the “Insurer”) to distribute funds to the Movant under a Debtor owned commercial liability insurance policy in settlement of any and all of the Movant’s claims. 2. The Motion, as filed, did not attach a proposed order. 3. The Movant subsequently submitted to Debtors’ counsel the draft proposed order attached hereto as Exhibit A (the “Proposed Order”) granting the relief sought in the Motion. 4. Counsel for the Debtors, the Office of the United States Trustee, the Debtors’ DIP Lender, and the Committee reviewed the Proposed Order and do not oppose its entry. Further, the Movant has advised Debtors’ counsel that counsel for the Insurer also does not oppose its entry. 5. Pursuant to the notice of the Motion [Docket No. 992], the deadline to file an objection to the Motion was October 27, 2021. As of the date of this Certification, no responses to the Motion appear on the docket.

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WHEREFORE, at the Movant’s request, counsel for the Debtors submits the Proposed Order for the Court’s consideration. Dated: November 9, 2021 COLE SCHOTZ P.C. /s/ Andrew J. Roth-Moore Norman L. Pernick (No. 2290) Justin R. Alberto (No. 5126) Patrick J. Reilley (No. 4451) Andrew J. Roth-Moore (No. 5988) 500 Delaware Avenue, Suite 1410 Wilmington, DE 19801 Telephone: (302) 652-3131 Facsimile: (302) 652-3117 npernick@coleschotz.com jalberto@coleschotz.com preilley@coleschotz.com aroth-moore@coleschotz.com Counsel to the Debtors and Debtors in Possession

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