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Full title: Certification of Counsel Regarding Motion for Entry of an Order Clarifying the Court's Vehicle Surrender Orders with Respect to Continuing Liabilities (related document(s)[895]) Filed by Advantage Holdco, Inc.. (Attachments: # (1) Exhibit A) (Roth-Moore, Andrew)

Document posted on Sep 14, 2021 in the bankruptcy, 2 pages and 0 tables.

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Re: Docket No. 895 CERTIFICATION OF COUNSEL REGARDING MOTION FOR ENTRY OF AN ORDER CLARIFYING THE COURT’S VEHICLE SURRENDER ORDERS WITH RESPECT TO CONTINUING LIABILITIES 907]; (ii) Objection by HFC Acceptance, LLC and Westlake Flooring Company, LLC to Motion for Entry of an Order Clarifying the Court’s Vehicle Surrender Orders with Respect to Continuing Liabilities Objection and Reservation of Rights of Element Fleet Corporation to Debtors’ Motion for Entry of an Order Clarifying the Court’s Vehicle Surrender Orders with Respect to Continuing Liabilities [Docket No. 909]; and (iv) Objection of Cox Automotive, Inc. to Debtors’ Motion for Entry of an Order Clarifying the Court’s Vehicle 1 Advantage Holdco, Inc. (4832); Advantage Opco, LLC (9101); Advantage Vehicles LLC (6217); E-Z Rent A Car, LLC (2538); Central Florida Paint & Body, LLC (1183); Advantage Vehicle Financing LLC (7263); and RAC At the direction of the Court, counsel to the Debtors, in conjunction with counsel to the Objectors, prepared the proposed form of order (the “Proposed Order”) attached hereto as Exhibit A.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 ADVANTAGE HOLDCO, INC., et al., Case No. 20-11259(CTG) Debtors.1 (Jointly Administered) Re: Docket No. 895 CERTIFICATION OF COUNSEL REGARDING MOTION FOR ENTRY OF AN ORDER CLARIFYING THE COURT’S VEHICLE SURRENDER ORDERS WITH RESPECT TO CONTINUING LIABILITIES The undersigned, counsel to the above-captioned debtors and debtors in possession (collectively, the “Debtors”), hereby certifies as follows: 1. On August 9, 2021 the Debtors filed the Motion for Entry of an Order Clarifying the Court’s Vehicle Surrender Orders with Respect to Continuing Liabilities [Docket No. 895] (the “Motion”). 2. Certain parties (collectively, the “Objectors”) filed objections to the Motion: (i) Objection of The Bancorp Bank to the Motion for Entry of an Order Clarifying the Court’s Vehicle Surrender Orders with Respect to Continuing Liabilities [Docket No. 907]; (ii) Objection by HFC Acceptance, LLC and Westlake Flooring Company, LLC to Motion for Entry of an Order Clarifying the Court’s Vehicle Surrender Orders with Respect to Continuing Liabilities [Docket No. 908]; (iii) Objection and Reservation of Rights of Element Fleet Corporation to Debtors’ Motion for Entry of an Order Clarifying the Court’s Vehicle Surrender Orders with Respect to Continuing Liabilities [Docket No. 909]; and (iv) Objection of Cox Automotive, Inc. to Debtors’ Motion for Entry of an Order Clarifying the Court’s Vehicle 1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, are: Advantage Holdco, Inc. (4832); Advantage Opco, LLC (9101); Advantage Vehicles LLC (6217); E-Z Rent A Car, LLC (2538); Central Florida Paint & Body, LLC (1183); Advantage Vehicle Financing LLC (7263); and RAC

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Surrender Orders with Respect to Continuing Liabilities [Docket No. 911]. Further, counsel for the Office of the U.S Trustee provided informal comments to the proposed order filed with the Motion. 3. On September 13, 2021, the Court held a non-evidentiary hearing on the Motion and denied the relief requested in the Motion. 4. At the direction of the Court, counsel to the Debtors, in conjunction with counsel to the Objectors, prepared the proposed form of order (the “Proposed Order”) attached hereto as Exhibit A. Further, a copy of the Proposed Order was circulated to the U.S. Trustee. 5. The Debtors and each Objector consents to the entry of the Proposed Order. Further, the U.S. Trustee does not oppose entry of the Proposed Order. WHEREFORE, the Debtors respectfully request the Court enter the Proposed Order at the Court’s earliest convenience. Dated: September 15, 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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