Case MFW Doc 831 Filed 03/25/16 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) )

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1 Case MFW Doc 831 Filed 03/25/16 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: SPORTS AUTHORITY HOLDINGS, INC., et al., 1 Debtors. Chapter 11 Case No (MFW (Jointly Administered Related Docket Nos.: 20, 157, 621, 642, 668, 748 Hearing Date: April 5, 2016 at 2:00 p.m. (ET JOINDER OF KIN PROPERTIES, INC., GAITSAN LIMITED PARTNERSHIP, PASAN TRUST, JEFAN TRUST, ESUE TRUST AND HALL PROPERTIES COMPANY TO CERTAIN LANDLORDS OBJECTIONS TO THE DEBTORS MOTION FOR INTERIM AND FINAL ORDERS AUTHORIZING DEBTORS TO OBTAIN POST-PETITION SECURED FINANCING Kin Properties, Inc.; Gaitsan Limited Partnership; Pasan Trust; Jefan Trust; Esue Trust; and Hall Properties Company (collectively, the KPI Landlords hereby object to the Debtors' Motion for Interim and Final Orders Authorizing Debtors to Obtain Post-Petition Secured Financing [Docket No. 20] (the DIP Motion, and in support thereof state as follows: 1. The KPI Landlords are the owners or managing agents for the owners of numerous shopping centers and retail properties located throughout the United States. The Debtors lease retail space from the KPI Landlords pursuant to leases (the Leases for the stores identified in the chart attached hereto as Exhibit The Debtors seek to obtain post-petition financing in order to operate outside of the ordinary course of business by selling their assets, including the KPI Landlords Leases. 1 The Debtors and the last four digits of their respective taxpayer identification numbers are as follows: Sports Authority Holdings, Inc. (9008; Slap Shot Holdings, Corp. (8209; The Sports Authority, Inc. (2802; TSA Stores, Inc. (1120; TSA Gift Card, Inc. (1918; TSA Ponce, Inc. (4817; and TSA Caribe, Inc. (5664. The headquarters for the above-captioned Debtors is located at 1050 West Hampden Avenue, Englewood, Colorado

2 Case MFW Doc 831 Filed 03/25/16 Page 2 of 3 3. The Approved DIP Budget, upon information and belief, does not provide for the payment of Stub Rent owed to the KPI Landlords for use of its properties from March 2, 2016 through March 31, 2016, and does not clearly provide for the payment of any post-petition rent. 4. Despite failing to provide for the payment of Stub Rent in the Approved Budget, the Debtors seek to waive their protections set forth in sections 506(c and 552(b of the Bankruptcy Code. 5. Carousel Center Company, L.P. et al., Brixmor Property Group, Inc. et al., Baker- Boca Raton, LLC et al., and James Campbell Company LLC et al., among other landlords, filed limited objections to the DIP Motion outlining the ways in which the DIP Motion forces landlords to pay for the liquidation of the secured creditors collateral without the ability to surcharge the secured creditors collateral pursuant to section 506(c and 552(b or the payment of Stub Rent to landlords [Docket Nos. 621, 642, 668, 748] (together, the Limited Objections. 6. The KPI Landlords hereby join in, adopt and incorporate by reference the Limited Objections as well as any other relevant objections to the DIP Motion filed by Debtors other landlords, for the reasons stated therein, including that the proposed DIP financing is materially unfair and contrary to law. 7. The entry of any final DIP order should be conditioned upon the Debtors immediate payment of all Stub Rent due to the KPI Landlords, and any waiver of the protections of 506(c and 522(b should be denied in the absence of payment of Stub Rent to the KPI Landlords. 8. The KPI Landlords reserve the right to supplement this joinder and make such other and further objections as may be necessary or appropriate. -2-

3 Case MFW Doc 831 Filed 03/25/16 Page 3 of 3 WHEREFORE, the KPI Landlords request that the Debtors DIP Motion be denied unless modified consistent with the Limited Objections and this joinder. Dated: March 25, 2016 Wilmington, Delaware BLANK ROME LLP /s/ Victoria A. Guilfoyle Victoria A. Guilfoyle (DE No Market Street, Suite 800 Telephone: ( Facsimile: ( Guilfoyle@BlankRome.com Jeffrey Rhodes 1825 Eye Street NW Washington, D.C Telephone: ( Facsimile: ( JRhodes@BlankRome.com Attorneys for Kin Properties, Inc.; Gaitsan Limited Partnership; Pasan Trust; Jefan Trust; Esue Trust; and Hall Properties Company -3-

4 Case MFW Doc Filed 03/25/16 Page 1 of 1 EXHIBIT 1 TSA Store # Kin Property # KPI Landlord Property Street Address Property City & State Gaitsan Limited Partnership 110 Odendhal Ave. Gaithersburg, Maryland Pasan Trust Jeffan Trust Esue Trust Hall Properties Co Mercury Drive Dearborn, Michigan 48126

5 Case MFW Doc Filed 03/25/16 Page 1 of 2 CERTIFICATE OF SERVICE I, Victoria A. Guilfoyle, hereby certify that on March 25, 2016, I served or caused to be served the foregoing Joinder of Kin Properties, Inc., Gaitsan Limited Partnership, Pasan Trust, Jefan Trust, Esue Trust and Hall Properties Company to Certain Landlords Objections to the Debtors Motion for Interim and Final Orders Authorizing Debtors to Obtain Post-Petition Secured Financing upon the persons listed on the attached service list via U.S. first-class mail, postage fully pre-paid. /s/ Victoria A. Guilfoyle Victoria A. Guilfoyle (DE No. 5183

6 Case MFW Doc Filed 03/25/16 Page 2 of 2 SERVICE LIST Robert A. Klyman, Esq. Matthew J. Williams, Esq. GIBSON, DUNN & CRUTCHER LLP 333 South Grand Avenue Los Angeles, California Donald E. Rothman, Esq. RIEMER & BRAUNSTEIN LLP Three Center Plaza Boston, Massachusetts Andreas Andromalos, Esq. BROWN RUDNICK, LLP One Financial Center Boston, Massachusetts Kevin J. Simard, Esq. CHOATE, HALL & STEWART LLP Two International Place Boston, Massachusetts Bradford J. Sandler, Esq. PACHULSKI STANG ZIEHL & JONES LLP 919 N. Market Street, 17 th Floor Jeffery N. Pomerantz, Esq. PACHULSKI STANG ZIEHL & JONES LLP Santa Monica Boulevard, 13 th Floor Los Angeles, California Michael R. Nestor, Esq. Andrew L. Magaziner, Esq. YOUNG CONAWAY STARGATT & TAYLOR, LLP Rodney Square, 1000 North King Street Gregory A. Taylor, Esq. ASHBY & GEDDES 500 Delaware Avenue Wilmington, Delaware Robert J. Stark, Esq. Bennett S. Silverberg, Esq. BROWN RUDNICK LLP Seven Times Square New York, New York Mark Collins, Esq. RICHARDS, LAYTON & FINGER, PA One Rodney Square 920 North King Street Wilmington, Delaware Robert J. Feinstein, Esq. Bradford J. Sandler, Esq. PACHULSKI STANG ZIEHL & JONES LLP 780 Third Avenue, 36 th Floor New York, New York Hannah McCollum, Esq. OFFICE OF THE U.S. TRUSTEE FOR THE DISTRICT OF DELAWARE 844 King Street, Suite 2207, Lockbox 35