Case MFW Doc 844 Filed 03/28/16 Page 1 of 3 UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE. Chapter 11. Case No.

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1 Case MFW Doc 844 Filed 03/28/16 Page 1 of 3 UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 Case No MFW SPORTS AUTHORITY HOLDINGS, INC., et al., Debtors. (Jointly Administered) Objection Date: April 12, 2016 at 4:00 p.m. (Objection date on Agenda submitted March 24, 2016 notes hearing on April 5, 2016, apparently as clerical error by Debtors) Hearing Date: April 26, 2016 at 11:30 a.m. Ref. Docket No. 67, 519, 525, 576, 599, 606, 617, 626, 658, 699, 742, 746, 751, 759, 778, 798, 830 LIMITED OBJECTION AND JOINDER OF LEVIN MANAGEMENT CORPORATION, AS AGENTS FOR IKEA PROPERTIES, INC. TO VARIOUS OBJECTIONS TO DEBTORS MOTION FOR ORDER EXTENDING THE TIME TO ASSUME OR REJECT UNEXPIRED LEASES OF NON-RESIDENTIAL REAL PROPERTY UNDER WHICH ANY OF THE DEBTORS ARE LESSEES Levin Management Corporation, as agent for Ikea Properties, Inc. (the Landlord ), by and through its undersigned counsel, hereby objects to the above-captioned debtors (the "Debtors") Motion for an Order, pursuant to 365(d)(4) of the Bankruptcy Code, Extending the Deadline by Which Debtors Must Assume or Reject Unexpired Leases of Non-Residential Real Property Under Which any of the Debtors are Lessees [Doc. No. 67] (the Motion ), and submits this Joinder to the Objections by other Landlords [Doc. Nos. 519, 525, 576, 599, 606, 617, 626, 658, 699, 742, 751, 759, 778, 798, and 830] (collectively, the Objections ), and respectfully states as follows: BACKGROUND 1. Landlord and Debtors are parties to a certain lease dated December 20, 2004 (the Lease ) for retail property located at Routes 4 and 17 in Paramus, N.J. (the Premises ). 2. On or about March 2, 2016 (the Petition Date ), each of Debtors commenced a 1

2 voluntary case under chapter 11 of the Bankruptcy Code with the United States Bankruptcy Court for the District of Delaware (the Court ). 3. Debtors filed the Motion seeking a ninety (90) day extension, through and including September 28, 2016, to assume or reject unexpired leases of non-residential real property, including the Lease. Case MFW Doc 844 Filed 03/28/16 Page 2 of 3 4. Landlord joins in, adopts and incorporates by reference the Objections, as well as any other relevant objections filed by Debtors other landlords. 5. Landlord reserves the right to supplement this Objection and make such other and further objections as may be necessary or appropriate. 6. The Court should condition any extension on: 1) Debtors timely payment of all amounts that come due under the Lease from and after the Petition Date during the period up to and including September 28, 2016, including, without limitation the Stub period rent due for March 2016; and 2) compliance with the covenant terms of the Lease. 7. Further, Landlord objects any extension of the deadline for assumption or rejection of the Lease past the confirmation of the plan of reorganization. WHEREFORE, Landlord respectfully requests that the Court enter an order: (i) conditioning approval of the Motion on the Debtors timely payment of all amounts that come due under the Lease after the Petition Date and compliance with the Lease terms; and (ii) granting such other and further relief as the Court deems just and proper. Dated: March 28, 2016 By: /s /John R. Weaver, Jr. John R. Weaver, Jr. P.O. Box W. 18th Street Wilmington, Delaware (302) (main) (302) (direct) jrweaverlaw@verizon.net 2

3 Case MFW Doc 844 Filed 03/28/16 Page 3 of 3 and Thomas S. Onder Timothy P. Duggan Joseph H. Lemkin 993 Lenox Drive Lawrenceville, NJ (609) (direct) (609) (main) (609) (facsimile) Attorneys for Levin Management Corporation, as Agent for Ikea Properties, Inc. 3

4 Case MFW Doc Filed 03/28/16 Page 1 of 3 UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 Case No MFW SPORTS AUTHORITY HOLDINGS, INC., et al., Debtors. (Jointly Administered) Objection Date: April 12, 2016 at 4:00 p.m. (Objection date on Agenda submitted March 24, 2016 notes hearing on April 5, 2016, apparently as clerical error by Debtors) Hearing Date: April 26, 2016 at 11:30 a.m. CERTIFICATION OF SERVICE OF LIMITED OBJECTION AND JOINDER OF LEVIN MANAGEMENT CORPORATION, AS AGENTS FOR IKEA PROPERTIES, INC. TO VARIOUS OBJECTIONS TO DEBTORS MOTION FOR ORDER EXTENDING THE TIME TO ASSUME OR REJECT UNEXPIRED LEASES OF NON-RESIDENTIAL REAL PROPERTY UNDER WHICH ANY OF THE DEBTORS ARE LESSEES John Weaver, Esquire hereby certifies that on the 28 th day of March, 2016, a true and correct copy of the Limited Objection and Joinder of Levin Management Corporation as Agent for Ikea Properties, Inc., landlords/creditors (the Landlord ), to the above-captioned debtors (The "Debtors") Motion for Order Extending the Time to Assume or Reject Unexpired Leases of Non-Residential Real Property Under Which Any of the Debtors are Lessees, was served upon the addressees listed on the attached service list in the manner indicated. Dated: March 28, 2016 By: /s /John R. Weaver, Jr. John R. Weaver, Jr. 1

5 Case MFW Doc Filed 03/28/16 Page 2 of 3 P.O. Box W. 18th Street Wilmington, Delaware (302) (main) (302) (direct) jrweaverlaw@verizon.net and Thomas S. Onder Timothy P. Duggan Joseph H. Lemkin 993 Lenox Drive Lawrenceville, NJ (609) (direct) (609) (main) (609) (facsimile) Attorneys for Levin Management Corporation as Agent for Ikea Properties, Inc. 2

6 Case MFW Doc Filed 03/28/16 Page 3 of 3 VIA CMECF and Regular Mail Jeremy L. Graves Gibson Dunn & Crutcher LLP 1801 California Street Suite 4200 Denver, CO Sabina Jacobs and Robert Klyman Gibson Dunn & Crutcher LLP 333 South Grand Avenue Los Angeles, CA Andrew L. Magaziner and Michael R. Nestor, Kenneth J. Enos Young Conaway Stargatt & Taylor LLP Rodney Square 1000 North King Street Wilmington, DE Alan J. Kornfeld and Jeffrey N. Pomerantz Pachulski Stang Ziehl & Jones LLP Santa Monica Blvd., 11 th Floor/13 th Floor Los Angeles, CA Proposed Co-Counsel for the Official Committee of Unsecured Creditors Bradford J. Sandler Pachulski Stang Ziehl & Jones LLP 919 N. Market Street, 17 th Floor Wilmington, DE Proposed Co-Counsel for the Official Committee of Unsecured Creditors Keith R. Martorana and Matt J. Williams Gibson Dunn & Crutcher LLP 200 Park Avenue New York, NY Hannah Mufson McCollum Office of the United States Trustee U.S. Department of Justice 844 King Street, Suite 2207 Wilmington, DE Robert J. Feinstein Pachulski Stang Ziehl & Jones LLP 780 Third Avenue, 36 th Floor New York, NY Proposed Co-Counsel for the Official Committee of Unsecured Creditors 3