Case MFW Doc 596 Filed 03/18/16 Page 1 of 4 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

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1 Case MFW Doc 596 Filed 03/18/16 Page 1 of 4 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 SPORTS AUTHORITY HOLDINGS, Case No (MFW INC., et al., Debtors. (Jointly Administered Re: Docket Nos. 6, 130 Obj. Deadline: 3/22/16, 4:00 p.m. Hearing Date: 3/29/16, 1:00 p.m. JOINDER OF CERTAIN ADDITIONAL UTILITY COMPANIES TO THE OBJECTION OF CERTAIN UTILITY COMPANIES TO THE DEBTORS MOTION FOR INTERIM AND FINAL ORDERS (A PROHIBITING UTILITY PROVIDERS FROM ALTERING, REFUSING OR DISCONTINUING SERVICE; (B APPROVING THE DEBTORS PROPOSED ADEQUATE ASSURANCE OF PAYMENT FOR POSTPETITION SERVICES; AND (C ESTABLISHING PROCEDURES FOR RESOLVING REQUESTS FOR ADDITIONAL ASSURANCE OF PAYMENT [Docket No. 544] Arizona Public Service Company ( APS, Jersey Central Power & Light Company ( JCP&L, Metropolitan Edison Company ( MetEd and Potomac Edison Company ( Potomac Edison (collectively, the Joinder Utilities, by counsel, hereby join in the Objection of Certain Utility Companies to the Debtors Motion For Interim and Final Orders (A Prohibiting Utility Providers From Altering, Refusing or Discontinuing Service; (B Approving the Debtors Proposed Adequate Assurance of Payment For Postpetition Services; and (C Establishing Procedures For Resolving Requests For Additional Adequate Assurance of Payment (the Objection, and

2 Case MFW Doc 596 Filed 03/18/16 Page 2 of 4 set forth the following: Introduction 1. The Joinder Utilities adopt and incorporate by reference herein the Introduction section set forth in the Objection. Facts 2. The Joinder Utilities adopt and incorporate by reference herein the Facts section set forth in the Objection. Facts Concerning the Utilities 3. The Joinder Utilities adopt and incorporate by reference herein the Facts Concerning the Utilities section set forth in the Objection. 4. In order to avoid the need to bring witnesses and have lengthy testimony regarding the Utilities regulated billing cycles, the Joinder Utilities request that this Court, pursuant to Rule 201 of the Federal Rules of Evidence, take judicial notice of the Joinder Utilities billing cycles. Pursuant to the foregoing request and based on the voluminous size of the applicable documents, the Joinder Utilities are providing the JCP&L: oice/new_jersey/new_jersey_tariffs.html MetEd: e/pennsylvania/pennsylvania_tariffs.html Potomac Edison: 2

3 Case MFW Doc 596 Filed 03/18/16 Page 3 of 4 ice/maryland/maryland_tariffs.html APS: 5. Subject to a reservation of the Joinder Utilities rights to supplement their post-petition deposit requests if additional accounts belonging to the Debtor are subsequently identified, the Joinder Utilities estimated prepetition debt and post-petition deposit requests are as follows: Utility No. of Accts. Est. Prepet. Debt Dep. Request JCP&L 8 $21, $30,254 (2-month MetEd 1 $6, $2,296 (2-month Potomac Edison 1 $1, $1,702 (2-month APS 5 $35, $116,220 (2.5 month Discussion 6. The Joinder Utilities incorporate and adopt by reference the legal and factual arguments set forth in the Objection. WHEREFORE, the Joinder Utilities respectfully request that this Court enter an order: Order; 1. Vacating the Injunctive Relief in the Interim Utility 2. Denying the Utility Motion as to the Joinder Utilities; 3. Awarding the Joinder Utilities the post-petition adequate assurance of payment pursuant to Section 366 in the 3

4 Case MFW Doc 596 Filed 03/18/16 Page 4 of 4 amount and form satisfactory to the Joinder Utilities; and 4. Providing such other and further relief as the Court deems just and appropriate. Dated: March 18, 2016 McCARTER & ENGLISH, LLP /s/ William F. Taylor, Jr. William F. Taylor, Jr. (#2936 Renaissance Centre 405 North King Street, 8 th Floor Wilmington, DE Telephone: ( Facsimile: ( wtaylor@mccarter.com; and Russell R. Johnson III John M. Craig Law Firm of Russell R. Johnson III, PLC 2258 Wheatlands Drive Manakin-Sabot, Virginia Telephone: ( Facsimile: ( russj4478@aol.com Counsel for Jersey Central Power & Light Company, Metropolitan Edison Company, Potomac Edison Company and Arizona Public Service Company 4

5 Case MFW Doc Filed 03/18/16 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 SPORTS AUTHORITY HOLDINGS, Case No (MFW INC., et al., Debtors. (Jointly Administered CERTIFICATE OF SERVICE I hereby certify that in addition to the notice and service provided through the Court s ECF system, on March 18, 2016, I caused a true and correct copy of the Joinder of Certain Additional Utility Companies To the Objection of Certain Utility Companies to the Debtors Motion For Interim and Final Orders (A Prohibiting Utility Providers From Altering, Refusing or Discontinuing Service; (B Approving the Debtors Proposed Adequate Assurance of Payment For Postpetition Services; and (C Establishing Procedures For Resolving Requests For Additional Adequate Assurance of Payment to be served by on: Michael R. Nestor Kenneth J. Enos Andrew L. Magaziner Young Conaway Stargatt & Taylor, LLP Rodney Square 1000 North King Street Wilmington, Delaware mnestor@ycst.com kenos@ycst.com amagaziner@ycst.com Debtors Counsel 1

6 Case MFW Doc Filed 03/18/16 Page 2 of 3 Robert A. Klyman Matthew J. Williams Jeremy L. Graves Sabina Jacobs Gibson, Dunn & Crutcher LLP 333 South Grand Avenue Los Angeles, California rklyman@gibsondunn.com mjwilliams@gibsondunn.com jgraves@gibsondunn.com sjacobs@gibsondunn.com Hannah Mufson McCollum Office of the United States Trustee U.S. Department of Justice 844 King Street, Suite 2207 Lockbox #35 Wilmington, Delaware hannah.mccollum@usdoj.gov Robert J. Feinstein Pachulski Stang Ziehl & Jones LLP 780 Third Avenue 36 th Floor New York, New York rfeinstein@pszjlaw.com Creditor Committee Counsel Alan J. Kornfeld Jeffrey N. Pomerantz Pachulski Stang Ziehl & Jones LLP Santa Monica Blvd., 11 th Floor Los Angeles, Califoria akornfeld@pszjlaw.com jpomerantz@pszjlaw.com Creditor Committee Counsel Bradford J. Sandler Pachulski Stang Ziehl & Jones LLP 919 N. Market Street, 17 th Floor Wilmington, Delaware bsandler@pszjlaw.com Creditor Committee Counsel 2

7 Case MFW Doc Filed 03/18/16 Page 3 of 3 By: McCARTER & ENGLISH, LLP /s/ William F. Taylor, Jr. William F. Taylor, Jr. (#2936 Renaissance Centre 405 North King Street, 8 th Floor Wilmington, DE Telephone: ( Facsimile: ( wtaylor@mccarter.com 3