UNITED STATES BANKRUPTCY COURT DISTRICT OF ARIZONA. All Debtors Specified Debtors

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1 Chad L. Schexnayder (No. 00) law.com Christopher R. Stovall (No. 0) law.com Kristin W. Mazon (No. 0) law.com JENNINGS, HAUG & CUNNINGHAM, L.L.P. 00 N. Central Avenue, Suite 00 Phoenix, AZ 00 Telephone: 0 00 Facsimile: 0 Attorneys for RideNow Management, LLC UNITED STATES BANKRUPTCY COURT DISTRICT OF ARIZONA In re: DEWEY RANCH HOCKEY, LLC COYOTES HOLDINGS, LLC COYOTES HOCKEY, LLC ARENA MANAGEMENT GROUP, LLC, This filing applies to: Debtors. All Debtors Specified Debtors Chapter Proceeding Case No.: :0 bk 0 (Jointly Administered) MOTION AND APPLICATION FOR PRODUCTION OF DOCUMENTS BY AND RULE 00 EXAMINATION OF DEBTORS 0 RideNow Management, LLC ( RideNow, Movant ), a creditor and partyin interest, by and through its undersigned counsel, hereby applies pursuant to Bankruptcy Rule 00 for an Order of this Court directing the Debtors () to produce for examination the materials and documents defined and requested in Exhibit ʺAʺ attached hereto at the law offices of Jennings, Haug & Cunningham, L.L.P., 00 North Central Avenue, Suite 00, Phoenix, Arizona on November, 00 at :00 a.m., and () to appear one week thereafter at the same location on

2 0 November, 00 at :00 a.m., or at such other time as may be set upon reasonable notice of the date and time of said examination being provided to Debtors and their counsel, for a Rule 00 examination concerning, among other purposes permitted under Rule 00, such materials and documents. In support thereof, Movant respectfully represents as follows:. On July, 00, Coyotes Hockey, LLC and RideNow Management, LLC entered into a letter agreement (the Sponsorship Agreement ) pursuant to which RideNow agreed to provide money and benefits to Coyotes, and the Coyotes agreed to provide tickets, advertising, promotion and sponsorship rights to RideNow.. On May, 00 (the Petition Date ), the Debtors filed their Voluntary Petitions for relief under Chapter of the Bankruptcy Code in the United States Bankruptcy Court for the District of Arizona (the Court ), which are jointly administered under the above referenced case number.. On August, 00, the Debtors filed their Debtors and Debtors in Possession Motion for an Order Authorizing the Assumption and Assignment of Executory Contracts and Unexpired Leases Under Section of the Bankruptcy Code in Connection with the Sale of Substantially All of Their Assets ( Debtors Motion ) [Docket No. ]. The Sponsorship Agreement is one of the allegedly executory contracts encompassed within the relief sought in Debtors Motion.. Debtors continue to act as debtor in possession in the bankruptcy case.. Pursuant to Rule 00, Rules of Bankruptcy Procedure, upon motion of any party in interest, the Court may order the examination of any person relating to the acts, conduct or property, or to the liabilities or financial condition of the Debtor or to any manner which may affect the administration of Debtorʹs estate, including the Debtor. See, In re Wilcher, B.R., (Bankr. N.D. Ill.

3 ).. Movant desires to examine the Debtors regarding the acts, conduct, property, liabilities and financial condition, among other matters which affect the bankruptcy estate and its administration, and with particular but not exclusive reference to the Sponsorship Agreement and the relief sought concerning it in Debtors Motion, and the materials and documents sought in the attached Exhibit A.. Movant requests an Order of this Court authorizing the Rule 00 examination of Debtors with production of the materials and documents defined and requested in the attached Exhibit ʺA,ʺ as follows: 0 (a) (b) That Debtors produce for examination and copying the materials and documents defined and requested in the attached Exhibit ʺAʺ at the law offices of Jennings, Haug & Cunningham, L.L.P., 00 North Central Avenue, Suite 00, Phoenix, Arizona on November, 00 at :00 a.m.; and, That Debtors appear at the same location one week thereafter on November, 00 at :00 a.m., or at such other time as may be set upon reasonable notice of the date and time of said examination being provided to Debtors and their counsel, for a Rule 00 examination concerning such materials and documents. WHEREFORE, Movant requests that this Court enter an Order requiring Debtors to produce at the time and place referenced above for examination and copying the materials and documents defined and requested in the attached Exhibit ʺA,ʺ and requiring Debtors to appear for a Bankruptcy Rule 00 examination at the time and place referenced above concerning the materials and

4 0 documents in Exhibit A. DATED this th day of October, 00. Filed electronically and copies mailed this th day of October, 00, to: Larry Lee Watson Office of the U. S. Trustee 0 North First Avenue, Suite 0 Phoenix, AZ 00 Via e mail: larry.watson@usdoj.gov Thomas J. Salerno tsalerno@ssd.com Jordan A. Kroop jkroop@ssd.com Kelly Singer ksinger@ssd.com Squire Sanders & Dempsey, LLP Two Renaissance Square 0 North Central Avenue, Suite 00 Phoenix, AZ 00 Attorneys for Debtors Susan Freeman sfreeman@lrlaw.com Lewis & Roca, LLP 0 North Central Avenue, Suite 00 Phoenix, AZ 00 Attorneys for PSE Sports & Entertainment LP and S&E Interim Facility Corporation Scott J. Greenberg scott.greenberg@cwt.com Cadwalader, Wickersham & Taft, LLP One World Financial Center New York, NY Attorneys for Ice Edge Holdings, LLC Kevin McCoy kmccoy@asbazlaw.com Paul Sala psala@asbazlaw.com Thomas H. Allen tallen@asbazlaw.com Allen, Sala & Bayne, PLC 0 North Central, Suite 0 Phoenix, AZ 00 Attorneys for the Official Joint Committee of Unsecured Creditor JENNINGS, HAUG & CUNNINGHAM, L.L.P. /s/ Chad L. Schexnayder (# 00) Chad L. Schexnayder Christopher R. Stovall Kristin W. Mazon Attorneys for RideNow Management, LLC

5 Alan Meda Stinson Morrison Hecker, LLP 0 North Central Avenue, Suite 0 Phoenix, AZ 00 Attorneys for National Hockey League /s/ Sheryl Higgins 0 0

6 0 Exhibit A. Each and every press release, handout, promulgation, public statement and announcement of any kind issued by or on behalf of any Debtor, or by or on behalf of Jerry Moyes, at any time from August, 00 through the present, concerning, referring to or relating to any potential sale, offer to purchase, and/or potential buyer, involving a potential relocation of the Coyotes NHL franchise, including but not limited to any to which James L. ʺJimʺ Balsillie or any entity in which he holds or held any direct or indirect interest or control is or was a putative or actual party.. Any and all correspondence, s, telephone messages and other documents, electronic files and recordings of any kind reflecting communications concerning, referring to or relating to any potential sale, offer to purchase, and/or potential buyer, involving potential relocation of the Coyotes NHL franchise, or concerning, referring to or relating to any proposed, draft or actual agreement for the purchase and sale of the Coyotes NHL franchise, all of the foregoing including but not limited to any to which James L. ʺJimʺ Balsillie or any entity in which he holds or held any direct or indirect interest or control is or was a putative or actual party.. Any and all documents, records, correspondence, s, telephone messages and other documents, electronic files and recordings of any kind, concerning, referring to or relating to the Letter of Agreement dated July, 00 between Coyotes Hockey, LLC and RideNow Management, LLC.. Any and all contracts and agreements with advertisers and/or sponsors for the Coyotes NHL franchise pertaining to the 00 0 season, and any and all proposals, quotes, communications, correspondence, s, telephone messages and other documents, electronic files and recordings of any kind concerning, referring to or relating to the same.. Any and all contracts and agreements concerning television, radio and/or Internet broadcasting and/or streaming of Coyotes NHL franchise games/events pertaining to the 00 0 season, and any and all proposals, quotes, communications, correspondence, s, telephone messages and other documents, electronic files and recordings of any kind concerning, referring to or relating to the same.. Any and all records, reports, communications, and other documents, electronic files and recordings of any kind, concerning, referring to or relating to the following: a. Coyotes NHL season ticket sales (by game, week, month, yearto date, year over year, annual, and otherwise) for the and 00 0 seasons; b. Coyotes NHL individual game ticket sales (by game, week, month, year to date, year over year, annual and otherwise) for the and 00 0 seasons; c. Coyotes NHL actual game attendance (by game, week, month, year to date, year over year, annual and otherwise) for the and 00 0 seasons;

7 d. Radio broadcast market share for Coyotes NHL game broadcasts during the and 00 0 seasons; e. Television broadcast market share for Coyotes NHL game broadcasts during the and 00 0 seasons; and, f. Data, statistics, and analyses of the demographic characteristics of purchasers of either season or individual game tickets during the and 00 0 seasons. 0