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Full title: Limited Objection and Reservation of Rights by HFC Acceptance, LLC and Westlake Flooring Company, LLC to Motion for Order Approving Disclosure Statement on an Interim Basis (etc.) (related document(s)[952]) Filed by HFC Acceptance, LLC and Westlake Flooring, LLC (Attachments: # (1) Exhibit 1 # (2) Certificate of Service) (Knight, John)

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

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LIMITED OBJECTION AND RESERVATION OF RIGHTS BY HFC ACCEPTANCE, LLC AND WESTLAKE FLOORING COMPANY, LLC TO MOTION FOR ORDER APPROVING DISCLOSURE STATEMENT ON AN INTERIM BASIS [ETC.]Debtors recently sought recovery of such alleged assets through a Motion to purportedly clarify an earlier order regarding surrender of fleet vehicles to various lessors and lenders, including LessorsAdvantage 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 Vehicle Financing, LLC (8375).To the extent that the Plan relies on the alleged positive fleet equity for its funding, Lessors believe the Disclosure Statement should make clear that many Fleet Lenders, including Lessors, dispute, and will continue to resist, any notion that they owe Debtors anything on account of alleged fleet equity. Counsel to HFC Acceptance, LLC, Westlake Flooring Company, LLC 2 A copy of the Clarification Objection is attached hereto as Exhibit 1, and provides more detail regarding Lessors’ position on the issue.

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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. 952 LIMITED OBJECTION AND RESERVATION OF RIGHTS BY HFC ACCEPTANCE, LLC AND WESTLAKE FLOORING COMPANY, LLC TO MOTION FOR ORDER APPROVING DISCLOSURE STATEMENT ON AN INTERIM BASIS [ETC.] 1. HFC Acceptance, LLC (“HFC”) and Westlake Flooring Company, LLC (“Westlake” and collectively with HFC, “Lessors”) submit this Limited Objection to the Motion for Order Approving Disclosure Statement (the “Disclosure Statement”) on an Interim Basis [etc.] [Dk. No. 952] (the “Motion”). 2. According to the Combined Disclosure Statement and Plan of Liquidation [Dk. No. 951] (the “Plan”), Debtors intend to pay certain Plan obligations from, among other things, “Residual Assets”. Residual Assets is defined to include “. . . claims against the Debtors’ fleet lenders relating to the disposition of the Debtors’ leased or financed vehicles, including but not limited to, liquidation/disposition recoveries in excess of amounts owed to such fleet lenders (i.e., “Positive Fleet Equity”).” Plan, Art. II, 118. 3. Yet, with respect to Lessors and perhaps other fleet lenders, there will likely be no such assets to recover. Debtors recently sought recovery of such alleged assets through a Motion to purportedly clarify an earlier order regarding surrender of fleet vehicles to various lessors and lenders, including Lessors [Dk. No. 895] (the “Clarification Motion”). Lessors (among others) 1 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 Vehicle Financing, LLC (8375). Debtors’ address is 2003 McCoy Road, Orlando, Florida 32809 (collectively, “Debtors”).

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objected to the Clarification Motion on the grounds that no amounts were owing to Debtors or that Debtors provided insufficient evidence and information to support their claims [Dk. No. 908] (the “Clarification Objection”).2 At the hearing on the Clarification Motion, the Court denied the motion without prejudice. 4. To the extent that the Plan relies on the alleged positive fleet equity for its funding, Lessors believe the Disclosure Statement should make clear that many Fleet Lenders, including Lessors, dispute, and will continue to resist, any notion that they owe Debtors anything on account of alleged fleet equity. Accordingly, Lessors reserve all rights with respect thereto. Dated: October 6, 2021 Wilmington, Delaware HFC ACCEPTANCE, LLC WESTLAKE FLOORING COMPANY, LLC /s/ John H. Knight John H. Knight (No. 3848) David T. Queroli (No. 6318) RICHARDS, LAYTON & FINGER, P.A. One Rodney Square 920 North King Street Wilmington, Delaware 19801 Telephone: (302) 651-7700 Facsimile: (302) 651-7701 Email: knight@rlf.com queroli@rlf.com – and – William S. Brody (admitted pro hac vice) Paul S. Arrow (admitted pro hac vice) BUCHALTER, A Professional Corporation 1000 Wilshire Boulevard, Suite 1500 Los Angeles, California 90017-1730 Telephone: (213) 891-0700 Facsimile: (213) 896-0400 Email: wbrody@buchalter.com Email: parrow@buchalter.com Counsel to HFC Acceptance, LLC, Westlake Flooring Company, LLC 2 A copy of the Clarification Objection is attached hereto as Exhibit 1, and provides more detail regarding Lessors’ position on the issue. 2

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