Case LSS Doc 662 Filed 07/18/17 Page 1 of 9 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

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1 Case LSS Doc 662 Filed 07/18/17 Page 1 of 9 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: EO Liquidating, LLC, et al., 1 Debtors. Chapter 11 Case No (LSS) (Jointly Administered) Obj. Deadline: August 18, 2017 at 4:00 p.m. (ET) Hearing Date: August 25, 2017 at 10:00 a.m. (ET) SECOND OMNIBUS OBJECTION (NON-SUBSTANTIVE) OF SPORTSDIRECT.COM RETAIL LTD. TO CLAIMS PURSUANT TO SECTIONS 105, 502(b), AND 503(b)(9) OF THE BANKRUPTCY CODE, BANKRUPTCY RULES 3003 AND 3007 AND LOCAL RULE **** Claimants receiving this Objection should locate their respective name and claim number on Exhibit A and/or Exhibit B attached to the Proposed Order annexed to the Objection as Exhibit 1, which contain the grounds for objections pertaining to their claim(s) and the relief being sought by Sportsdirect. Your substantive rights may be affected by this Objection and by any further objection that may be filed by Sportsdirect and/or the Debtors. The relief sought herein is without prejudice to the Debtors rights to pursue further substantive or non-substantive objections against the claims listed in Exhibit A and/or Exhibit B attached to the Proposed Order. **** 1 The Debtors and the last four digits of their respective federal taxpayer identification numbers, where applicable, are as follows: EO Liquidating, LLC (9164); Subortis Retail Financing, LLC (9065); EM Liquidating, LLC (9553); Subortis IP Holdings, LLC; BS Liquidating, LLC (4389); and BS/EM Liquidating, LLC (9618). The Debtors executive headquarters are located at 160 Corporate Court, Meriden, CT

2 Case LSS Doc 662 Filed 07/18/17 Page 2 of 9 Sportdirect.com Retail Ltd. ( Sportsdirect ), having assumed certain liabilities of the above-captioned debtors and debtors-in-possession (collectively, the Debtors ), hereby objects (the Objection ) to certain filed claims that assert administrative expense status under section 503(b)(9) (collectively, the 503(b)(9) Claims ) of title 11 of the United States Code, 11 U.S.C. 101, et seq. (the Bankruptcy Code ), on the grounds that: (A) the claims listed in Exhibit A annexed to the Proposed Order are duplicative of previously filed 503(b)(9) Claims (collectively, the Duplicate Claims ); and (ii) the claim listed in Exhibit B annexed to the Proposed Order failed to provide backup documentation and the Debtors and their retained professionals were not able to reconcile the claim with the Debtors books and records (collectively, the Insufficient Documentation Claim ). In support of this Objection, Sportsdirect submits the Declaration of Daniel Bliss, the Debtors Vice President of Finance, attached hereto as Exhibit 2, and respectfully state: Status of the Case and General Background 1. On February 5, 2017 (the Petition Date ), the Debtors commenced these chapter 11 cases by filing voluntary petitions for relief under chapter 11 of the Bankruptcy Code with the United States Bankruptcy Court for the District of Delaware (the Court ). 2. The Debtors have continued in possession of their properties and are operating and managing their businesses as debtors-in-possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 3. On February 15, 2017, the Office of the United States Trustee appointed an official committee of unsecured creditors (the Committee ) [Docket No. 96]. No request has been made for the appointment of a trustee or examiner pursuant to section 1104 of the Bankruptcy Code. 2

3 Case LSS Doc 662 Filed 07/18/17 Page 3 of 9 4. On February 9, 2017, the Debtors filed that certain Asset Purchase Agreement by and among the Debtors and Sportsdirect, dated as of February 8, 2017 [Docket No. 63] (as amended or restated from time to time, the APA ). 5. On February 10, 2017, the Debtors filed the Debtors Motion for Orders (A)(I) Authorizing and Approving Bidding Procedures, Break-Fee and Expense Reimbursement; (II) Authorizing and Approving the Debtors Entry Into the Stalking Horse APA; (III) Approving Notice Procedures; (IV) Scheduling a Sale Hearing; and (V) Approving Procedures for Assumption and Assignment of Executory Contracts and Unexpired Leases and Determining Cure Amounts and (B)(I) Authorizing the Sale of Substantially All of the Debtors Assets Free and Clear of All Claims, Liens, Rights, Interests, and Encumbrances; (II) Approving the Stalking Horse APA; and (III) Authorizing the Debtors to Assume and Assign Certain Executory Contracts and Unexpired Leases [Docket No. 76] (the Sale Motion ), seeking, among other things, entry of an order authorizing the Debtors entry into the APA and the sale of substantially all of the Debtors assets (the Sale ) to Sportsdirect. 6. On April 19, 2017 the Court entered the Order (I) Authorizing the Sale of Substantially All of the Debtors Assets Free and Clear of Claims, Liens, Rights, Interests, and Encumbrances, (II) Approving the Asset Purchase Agreement and (III) Authorizing the Debtors to Assume and Assign Certain Executory Contracts and Unexpired Leases [Docket No. 435] (as amended by that certain Order Granting Debtors Motion Pursuant to Local Rule (k) for an Order Approving Request for Amendment of Order (I) Authorizing the Sale of Substantially All of the Debtors Assets Free and Clear of Claims, Liens, Rights, Interests, and Encumbrances, (II) Approving the Assets Purchase Agreement and (III) Authorizing the Debtors to Assume and 3

4 Case LSS Doc 662 Filed 07/18/17 Page 4 of 9 Assign Certain Executory Contracts and Unexpired Leases [Docket No. 524], the Sale Order ) Pursuant to paragraph 16 of the Sale Order, Sportsdirect has standing to object to the validity, amount, or priority of any claim against the Debtors to the extent it would otherwise constitute an Assumed Liability. 8. Pursuant to the APA, Sportsdirect agreed to assume and pay up to $800,000 of the 503(b)(9) Claims to the extent allowed by the Court and not otherwise paid by the Debtors prior to the closing of the Sale. Furthermore, Sportsdirect has 60 days following the closing of the Sale to object to duly filed 503(b)(9) Claims. 9. The Sale closed on May 18, 2017 [Docket No. 555]. Jurisdiction, Venue, and Statutory Predicates 10. The Court has jurisdiction over this Objection pursuant to 28 U.S.C. 157 and Venue is proper in this district pursuant to 28 U.S.C and This matter is core within the meaning of 28 U.S.C. 157(b)(2). 11. The statutory predicates for the relief sought herein are sections 105, 502(b), and 503(b)(9) of the Bankruptcy Code, Rules 3003 and 3007 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ), and Rule of the Local Rules for the United States Bankruptcy Court for the District of Delaware (the Local Rules ). 503(b)(9) Claims Bar Date 12. On April 24, 2017, the Court entered the Order (I) Fixing Bar Date For Filing Claims Arising Under Section 503(b)(9) of the Bankruptcy Code and Certain Post-Petition Administrative Expense Claims and (II) Approving the Form and Manner of Notice of the Bar Date [Docket No. 456] (the 503(b)(9) Bar Date Order ), which established May 31, 2017 as the 2 Capitalized terms not otherwise defined herein shall have the meanings given to them in the Sale Order or the APA, as applicable. 4

5 Case LSS Doc 662 Filed 07/18/17 Page 5 of 9 last date for all creditors holding a 503(b)(9) Claim against one or more of the Debtors to file and serve a written proof of claim for payment of any such claim (the 503(b)(9) Bar Date ). Notice of the 503(b)(9) Bar Date Order was provided in accordance with the procedures outlined in the order. 13. In the ordinary course of business, the Debtors maintained books and records (collectively, the Books and Records ) that reflect, among other things, the Debtors aggregate liabilities and the specific amounts owed to each of their creditors. The Debtors and their professionals have reviewed, and are continuing to review, the 503(b)(9) Claims and have begun reconciling those claims with the Books and Records. This process includes identifying categories of claims that may be targeted for disallowance, reduction and/or reclassification. Relief Requested 14. By this Objection, Sportsdirect seeks entry of an order: (i) disallowing the Duplicate Claims listed in Exhibit A attached to the Proposed Order, and (ii) disallowing the Insufficient Documentation Claim listed in Exhibit B attached to the Proposed Order. Basis for Relief Requested A. Duplicate Claims (Exhibit A) 15. Sportsdirect objects to each of the claims listed in Exhibit A to the Proposed Order on the ground that each Duplicate Claim is a proof of claim which is a duplicate of a previously filed 503(b)(9) Claim. Given that neither Sportsdirect nor the Debtors estates can be required to pay on the same 503(b)(9) Claim more than once, Sportsdirect objects to each Duplicate Claim and seeks entry of an order disallowing the Duplicate Claims in their entirety. See In re Aleris Int l, Inc., Case No (Bankr. D. Del. Dec. 10, 2009) (order disallowing and expunging claims filed by individual noteholders because the claims were duplicative of those filed by indenture trustees of the notes); In re Dura Automotive Sys., Inc., Case No. 06-5

6 Case LSS Doc 662 Filed 07/18/17 Page 6 of (Bankr. D. Del. Nov. 1, 2007) [Docket No. 2135] (same). Accordingly, each Duplicate Claim in Exhibit A attached to the Proposed Order should be disallowed. B. Insufficient Documentation Claim (Exhibit B) 16. Sportsdirect objects to the 503(b)(9) Claim listed in Exhibit B to the Proposed Order on the ground that the claimant of the Insufficient Documentation Claim failed to annex supporting documentation for the 503(b)(9) Claim and the Debtors and their retained professionals were not able reconcile the Insufficient Documentation Claim with the Books and Records. 17. Section 502(a) of the Bankruptcy Code provides that [a] claim or interest, proof of which is filed under section 501 of this title, is deemed allowed, unless a party in interest... objects. 11 U.S.C. 502(a). The burden of proof for determining the validity of claims rests on different parties at different stages of the objection process. As explained by the Third Circuit: The burden of proof for claims brought in bankruptcy court under 11 U.S.C. 502(a) rests on different parties at different times. Initially, the claimant must allege facts sufficient to support the claim. If the averments in his filed claim meet this standard of sufficiency, it is prima facie valid [citations omitted]. In other words, a claim that alleges facts sufficient to support legal liability to the claimant satisfies the claimants initial obligation to go forward. The burden of going forward then shifts to the objector to produce evidence sufficient to negate the prima facie validity of the filed claim... In practice, the objector must produce evidence which, if believed, would refute at least one of the allegations that is essential to the claim s legal sufficiency. If the objector produces sufficient evidence to negate one or more of the sworn facts in the proof of claim, the burden reverts to the claimant to prove the validity of the claim by a preponderance of the evidence. In re Allegheny Int l Inc., 954 F.2d 167, (3d. Cir. 1992) (citation omitted). Once the prima facie validity of a claim is rebutted, it is for the claimant to prove his claim, not for the objector to disprove it. In re Kahn, 114 B.R. 40, 44 (Bankr. S.D.N.Y. 1990) (citations omitted). 18. The Debtors and their retained professionals have reviewed and compared the Insufficient Documentation Claim to the Books and Records, made reasonable efforts to research the Insufficient Documentation Claim, and determined that the Insufficient Documentation 6

7 Case LSS Doc 662 Filed 07/18/17 Page 7 of 9 Claim erroneously asserts a claim against the Debtors and therefore should be disallowed as set forth in Exhibit B. Thus, Sportsdirect objects to the Insufficient Documentation Claim on the basis that neither the Books and Records nor the type and basis of the Insufficient Documentation Claim asserted suggests that the asserted claim should be allowed and granted the priority status asserted. Accordingly, the Insufficient Documentation Claim should be disallowed as set forth in Exhibit B. Reservation of Rights 19. Sportsdirect expressly reserves the right to amend, modify or supplement this Objection and to file additional objections to the Duplicate Claims, the Insufficient Documentation Claim, or to any other proofs of claim that may be asserted against the Debtors estates. Should one or more of the grounds of objection stated herein be overruled, Sportsdirect reserves the right to object to these claims on any other ground that bankruptcy or nonbankruptcy law permits. Compliance with Local Rule Sportsdirect, by and through its counsel, states that, to the best of its knowledge, information and belief, this Objection and related exhibits comply with the requirements of Local Rule To the extent this Objection does not comply in all respects with the requirements of Local Rule , the undersigned believes such deviations are not material and respectfully requests that such requirements be waived. Notice 21. Notice of this Objection has been given to the following parties or, in lieu thereof, to their counsel, if known: (a) the Office of the United States Trustee for the District of Delaware; (b) counsel to the Debtors; (c) counsel to the Committee; (d) those parties requesting notice, pursuant to Bankruptcy Rule 2002; and (e) those parties whose claims are listed in 7

8 Case LSS Doc 662 Filed 07/18/17 Page 8 of 9 Exhibit A and/or Exhibit B to the Proposed Order. Sportsdirect submits that, in light of the nature of the relief requested, no other or further notice need be given. Conclusion WHEREFORE, for the reasons set forth herein, Sportsdirect respectfully requests that this Court approve the relief requested in this Objection and grant such other and further relief as is just and proper. [Signature on next page] 8

9 Case LSS Doc 662 Filed 07/18/17 Page 9 of 9 Dated: July 18, 2017 GREENBERG TRAURIG, LLP /s/ Dennis A. Meloro Dennis A. Meloro (DE Bar No. 4435) The Nemours Building 1007 North Orange Street, Suite 1200 Wilmington, Delaware Telephone: (302) Facsimile: (302) melorod@gtlaw.com - and - Nancy A. Mitchell (admitted pro hac vice) Matthew L. Hinker (DE Bar No. 5348) The MetLife Building 200 Park Avenue New York, New York Telephone: (212) Facsimile: (212) mitchelln@gtlaw.com hinkerm@gtlaw.com Counsel for Sportsdirect.com Retail Ltd. 9

10 Case LSS Doc Filed 07/18/17 Page 1 of 8 Exhibit 1 Proposed Order

11 Case LSS Doc Filed 07/18/17 Page 2 of 8 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: EO Liquidating, LLC, et al., 1 Debtors. Chapter 11 Case No (LSS) (Jointly Administered) Ref. Docket No. ORDER GRANTING SECOND OMNIBUS OBJECTION (NON-SUBSTANTIVE) OF SPORTSDIRECT.COM RETAIL LTD. TO CLAIMS PURSUANT TO SECTIONS 105, 502(b), AND 503(b)(9) OF THE BANKRUPTCY CODE, BANKRUPTCY RULES 3003 AND 3007 AND LOCAL RULE Upon the Objection 2 filed by Sportsdirect seeking entry of an order (this Order ): (i) disallowing the Duplicate Claims listed in Exhibit A attached hereto, and (ii) disallowing the Insufficient Documentation Claim listed in Exhibit B attached hereto; and it appearing that venue of these chapter 11 cases and the Objection in this district is proper pursuant to 28 U.S.C and 1409; and it appearing that this matter is a core proceeding pursuant to 28 U.S.C. 157(b); and this Court having found that the relief requested in the Objection is in the best interests of the Debtors, their estates, their creditors and other parties in interest; and it appearing that proper and adequate notice of the Objection has been given and that no other or further notice is necessary; and after due deliberation thereon; and this Court having reviewed the Objection; and good and sufficient cause appearing therefor; 1 The Debtors and the last four digits of their respective federal taxpayer identification numbers, where applicable, are as follows: EO Liquidating, LLC (9164); Subortis Retail Financing, LLC (9065); EM Liquidating, LLC (9553); Subortis IP Holdings, LLC; BS Liquidating, LLC (4389); and BS/EM Liquidating, LLC (9618). The Debtors executive headquarters are located at 160 Corporate Court, Meriden, CT Capitalized terms not otherwise defined herein shall the meanings ascribed to them in the Objection.

12 Case LSS Doc Filed 07/18/17 Page 3 of 8 IT IS HEREBY ORDERED THAT: 1. The Objection is GRANTED as set forth herein. 2. Each Duplicate Claim is hereby disallowed as set forth in Exhibit A attached hereto. 3. The Insufficient Documentation Claim is hereby disallowed as set forth in Exhibit B attached hereto. 4. The claims agent shall amend the claims register maintained in the chapter 11 cases to conform to this Order. 5. Each Duplicate Claim and Insufficient Documentation Claim and the Objection by Sportsdirect to such claims, as addressed in the Objection and the exhibits attached hereto, constitutes a separate contested matter as contemplated by Bankruptcy Rule 9014 and Local Rule This Order shall be deemed a separate Order with respect to each claim. Any stay of this Order pending appeal by any claimant whose claim is subject to this Order shall only apply to the contested matter which involves such claimant and shall not act to stay the applicability and/or finality of this Order with respect to the other contested matters listed in the Objection or this Order. 6. Notwithstanding the possible applicability of Bankruptcy Rules 6004, 7062, 9014, or otherwise, the terms and conditions of this Order shall be immediately effective and enforceable upon its entry. All time periods set forth in the Order shall be calculated in accordance with Bankruptcy Rule 9006(a). 2

13 Case LSS Doc Filed 07/18/17 Page 4 of 8 7. This Court shall retain jurisdiction with respect to all matters arising from or relating to the interpretation or implementation of this Order. Dated:, 2017 HONORABLE LAURIE SELBER SILVERSTEIN UNITED STATES BANKRUPTCY JUDGE 3

14 Case LSS Doc Filed 07/18/17 Page 5 of 8 Exhibit A Duplicate Claims

15 Case LSS Doc Filed 07/18/17 Page 6 of 8 Exhibit A: Duplicate Claims # CLAIM NAME ADDRESS Objectionable Claims CLAIM NUMBER DEBTOR NAME CASE NUMBER 503 (b) (9) ADMIN CLAIMED AMOUNT REASON # CLAIM NAME ADDRESS SURVIVING CLAIMS CLAIM NUMBER DEBTOR NAME CASE NUMBER SURVIVING 503 (b) (9) ADMIN CLAIMED AMOUNT 1 Fownes Performance Group 2 Fownes Performance Group Attn: Thomas Faivre 16 East 34th Street 5th Floor NY, NY Eastern Mountain Sports, LLC $23, Attn: Thomas Faivre 16 East 34th Street 5th Floor NY, NY Eastern Mountain Sports, LLC $23, Claim is duplicative of another Claim filed in these Chapter 11 Cases. Review of the Claim shows that only the Debtor for the Surviving Claim is liable for the asserted 503(b)(9) Claim. Therefore, Sportsdirect objects to the Duplicative Claim. Please note claim 204 is duplicative of surviving claim 103. Claim is duplicative of another Claim filed in these Chapter 11 Cases. Review of the Claim shows that only the Debtor for the Surviving Claim is liable for the asserted 503(b)(9) Claim. Therefore, Sportsdirect objects to the Duplicative Claim. Please note claim 205 is duplicative of surviving claim Fownes Performance Group Attn: Thomas Faivre 16 East 34th Street 5th Floor NY, NY Eastern Mountain Sports, LLC $ 23, Fownes Performance Group Attn: Thomas Faivre 16 East 34th Street 5th Floor NY, NY Eastern Mountain Sports, LLC $23, Claim is duplicative of another Claim filed in these Chapter 11 Cases. Review of the Claim shows that only the Debtor for the Surviving Claim is liable for the asserted 503(b)(9) Claim. Therefore, Sportsdirect objects to the Duplicative Claim. Please note claim 206 is duplicative of surviving claim Valassis, Inc. 5 Valassis, Inc. Attn: R. Michele Pinckney One Targeting Centre Windsor, Ct Bob's Store, LLC $14, Attn: R. Michele Pinckney One Targeting Centre Windsor, Ct Bob's Store, LLC $14, Claim is duplicative of another Claim filed in these Chapter 11 Cases. Review of the Claim shows that only the Debtor for the Surviving Claim is liable for the asserted 503(b)(9) Claim. Therefore, Sportsdirect objects to the Duplicative Claim. Further, the Debtor and the creditor have negotiated an agreement eliminating filed claim 142. Claim is duplicative of another Claim filed in these Chapter 11 Cases. Review of the Claim shows that only the Debtor for the Surviving Claim is liable for the asserted 503(b)(9) Claim. Therefore, Sportsdirect objects to the Duplicative Claim. Further, the Debtor and the creditor have negotiated an agreement eliminating filed claim N/A N/A N/A N/A N/A N/A Page 1 of 1

16 Case LSS Doc Filed 07/18/17 Page 7 of 8 Exhibit B Insufficient Documentation Claim

17 Case LSS Doc Filed 07/18/17 Page 8 of 8 Exhibit B: Insufficient Documentation Claim # CLAIM NAME ADDRESS 1 Alba I Espinal 103 Cluff Crossing Rd. M7 Salem, NH CLAIM NUMBER DEBTOR NAME CASE NUMBER CLAIMED STATUS CLAIMED AMOUNT 160 Eastern Outfitters, LLC (b) (9) ADMIN $23, REASON FOR DISALLOWANCE Claimant fails to provide any support for its asserted priority status; and Sportsdirect objects to the asserted classification. Moreover, there is no outstanding 503(b)(9) liability or connection to the claimant per the Debtors Books and Records and a review of the Claim. Page 1 of 1

18 Case LSS Doc Filed 07/18/17 Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: EO Liquidating, LLC, et al., 1 Debtors. Chapter 11 Case No (LSS) (Jointly Administered) Obj. Deadline: August 18, 2017 at 4:00 p.m. (ET) Hearing Date: August 25, 2017 at 10:00 a.m. (ET) NOTICE OF SECOND OMNIBUS OBJECTION (NON-SUBSTANTIVE) OF SPORTSDIRECT.COM RETAIL LTD. TO CLAIMS PURSUANT TO SECTIONS 105, 502(b), AND 503(b)(9) OF THE BANKRUPTCY CODE, BANKRUPTCY RULES 3003 AND 3007 AND LOCAL RULE TO THOSE HOLDERS OF CLAIMS ON EXHIBITS A AND B TO THE PROPOSED ORDER, ANNEXED TO THE OBJECTION AS EXHIBIT 1: YOUR SUBSTANTIVE RIGHTS MAY BE AFFECTED BY THIS OBJECTION AND BY ANY FURTHER OBJECTION THAT MAY BE FILED BY SPORTSDIRECT.COM RETAIL LTD. AND/OR THE DEBTORS; YOU ARE DIRECTED TO LOCATE YOUR CLAIM ON THE EXHIBITS TO THE PROPOSED ORDER; THE RELIEF SOUGHT HEREIN IS WITHOUT PREJUDICE TO THE DEBTORS RIGHTS TO PURSUE FURTHER SUBSTANTIVE OR NON- SUBSTANTIVE OBJECTIONS AGAINST THE CLAIMS ADDRESSED HEREIN. PLEASE TAKE NOTICE that Sportsdirect.com Retail Ltd. ( Sportsdirect ), by and through its undersigned counsel, filed the attached Second Omnibus Objection (Non-Substantive) of Sportsdirect.com Retail Ltd. to Claims Pursuant to Sections 105, 502(b), and 503(b)(9) of the Bankruptcy Code, Bankruptcy Rules 3003 and 3007 and Local Rule (the Objection ). PLEASE TAKE FURTHER NOTICE that responses, if any, to the Objection must be made in writing, filed with the United States Bankruptcy Court for the District of Delaware, 824 North Market Street, Wilmington, Delaware 19801, and served so as to be received by undersigned counsel no later than AUGUST 18, 2017 at 4:00 p.m. (Prevailing Eastern Time). 1 The Debtors and the last four digits of their respective federal taxpayer identification numbers, where applicable, are as follows: EO Liquidating, LLC (9164); Subortis Retail financing, LLC (9065); EM Liquidating, LLC (9553); Subortis IP Holdings, LLC; BS Liquidating, LLC (4389); and BS/EM Liquidating, LLC (9618). The Debtors executive headquarters are located at 160 Corporate Court, Meriden, CT NY v1

19 Case LSS Doc Filed 07/18/17 Page 2 of 2 PLEASE TAKE FURTHER NOTICE that any response or opposition to the Objection must contain, at a minimum, the following: (a) a caption setting forth the name of the Court, the name of the Debtors, the case number and the title of the Objection; (b) the name of the claimant and a description of the basis for the amount and priority of the relevant asserted claim, including a concise statement setting forth the reasons why the relevant asserted claim should not be reclassified for the reasons set forth in the Objection, including, but not limited to, the specific factual and legal basis upon which the claimant will rely in opposing the Objection; (c) all documentation or other evidence of the claim, to the extent not included with the proof of claim previously filed with the Debtors claims agent, upon which the claimant will rely in opposing the Objection at the hearing; and (d) the name, address, and telephone number of the person (which may be the claimant or the claimant s legal representative) possessing ultimate authority to reconcile, settle, or otherwise resolve the claim on behalf of the claimant. PLEASE TAKE FURTHER NOTICE that if no responses to the Objection are timely filed and received in accordance with the procedures set forth above, an order may be entered granting the relief requested in the Objection without further notice or a hearing. If a response is properly filed and served in accordance with the procedures set forth above, a hearing on the Objection will be held on August 25, 2017 at 10:00 a.m. (Prevailing Eastern Time), or such other date and time as parties filing responses may be notified, before the Honorable Laure S. Silverstein, United States Bankruptcy Court Judge for the District of Delaware, in the United States Bankruptcy Court, 824 North Market Street, 6th Floor, Courtroom 2, Wilmington, Delaware Only responses made in writing and timely filed and received will be considered by the Bankruptcy Court at such hearing. IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF REQUESTED BY THE OBJECTION WITHOUT FURTHER NOTICE OR HEARING. GREENBERG TRAURIG, LLP /s/ Dennis A. Meloro Dennis A. Meloro (DE Bar No. 4435) The Nemours Building 1007 North Orange Street, Suite 1200 Wilmington, Delaware Telephone: (302) Facsimile: (302) melorod@gtlaw.com Dated: July18, 2017 Nancy A. Mitchell (admitted pro hac vice) Matthew L. Hinker (DE Bar No. 5348) The MetLife Building 200 Park Avenue New York, New York Telephone: (212) Facsimile: (212) mitchelln@gtlaw.com hinkerm@gtlaw.com Counsel for Sportsdirect.com Retail Ltd. NY v1 2