Case LSS Doc 378 Filed 04/12/17 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE.

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1 Case LSS Doc 378 Filed 04/12/17 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: EASTERN OUTFITTERS, LLC, at al., 1 Debtors. Chapter 11 Case No (LSS) (Jointly Administered) Hearing Date: April 19, 2017 at 9:00 a.m. Objections Due: April 12, 2017 at 4:00 p.m. COR ROUTE 5 COMPANY, LLC S OBJECTION TO THE CURE AMOUNT LISTED IN DEBTORS NOTICE OF (I) POSSIBLE TREATMENT OF EXECUTORY CONTRACTS AND LEASES, (II) FIXING OF CURE AMOUNTS AND (III) DEADLINE TO OBJECT [D.I. No. 272] COR Route 5 Company, LLC ( COR ), by and through its undersigned counsel, hereby files this limited objection to the Debtors Notice of (I) Possible Treatment of Executory Contracts and Leases, (II) Fixing of Cure Amounts and (III) Deadline to Object [D.I. No. 272] (the Cure Notice ) 2 and the Debtors Notice of Filing of Revised Exhibit A to Notice of (I) Possible Treatment of Executory Contracts and Leases, (II) Fixing of Cure Amounts and (III) Deadline to Object [D.I. No 273] (the Revised Cure Schedule ). In support of this objection, COR respectfully represents as follows: 1. The Debtor Eastern Mountain Sports, LLC (through its predecessor-in-interest, Eastern Mountain Sports, Inc.) and COR are parties to a lease dated April 16, 2003 and subsequently amended on July 22, 2010, July 31, 2015, and October 11, 2016 (the Lease ), for the premises located at 531 Towne Drive, Fayetteville, New York (the Store ). 2. The Store is located in an unenclosed shopping center and is commonly referred to by the Debtors as Store Number The Debtors and the last four digits of their respective federal taxpayer identification numbers, where applicable, are as follows: Eastern Outfitters, LLC (9164); Subortis Retail Financing, LLC (9065); Eastern Mountain Sports, LLC (9553); Subortis IP Holdings, LLC, Bob s Stores, LLC (4389); and Bob s/ems Gift Card, LLC (9618). The Debtors executive headquarters are located at 160 Corporate Court, Meriden, CT Capitalized terms not defined herein shall have the meaning ascribed to them in the Cure Notice.

2 Case LSS Doc 378 Filed 04/12/17 Page 2 of 3 3. On Revised Schedule A, the Debtors have proposed a pre-petition cure amount of $17, (the Proposed Cure Amount ) for the Lease. 4. COR objects to the Proposed Cure Amount as it is not accurate. 5. According to its records, COR is currently owed pre-petition arrears in the amount of $111, COR is also entitled, pursuant to the terms of the Lease and section 365(b)(1)(B) of the Bankruptcy Code, to reimbursement of its actual pecuniary loss, including reasonable attorneys fees and costs incurred as a result of the Debtors defaults. 6. In addition to the pre-petition arrears, it should be noted that COR is owed postpetition arrears in the amount of $4, for unpaid rent. 7. Further, COR reserves its right to supplement this objection and the actual cure amount to reflect any costs incurred through the effective date of any assumption and assignment of the Lease. 8. This objection solely relates to the Proposed Cure Amount and should not be interpreted as consent to any treatment of the Lease under the Bankruptcy Code or waiver of any objections and defenses thereto. WHEREFORE, COR respectfully requests that the Court enter an order (1) setting COR s pre-petition cure amount at $111,629.15, subject to future adjustment for any pecuniary loss, and (2) granting such other and further relief as the Court deems just and proper. [The remainder of this page is intentionally left blank.]

3 Case LSS Doc 378 Filed 04/12/17 Page 3 of 3 BIELLI & KLAUDER, LLC Dated: April 12, 2017 By: /s/ Cory P. Stephenson David M. Klauder (No. 5769) Cory P. Stephenson (No. 6097) 1204 N. King Street Phone: Fax: dklauder@bk-legal.com cstephenson@bk-legal.com and BOND, SCHOENECK & KING, PLLC Stephen A. Donato (pro hac vice admission pending) Sarah M. Harvey (pro hac vice admission pending) One Lincoln Center Syracuse, New York Phone: Fax: sharvey@bsk.com donatos@bsk.com Counsel to COR Route 5 Company, LLC

4 Case LSS Doc Filed 04/12/17 Page 1 of 1 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: EASTERN OUTFITTERS, LLC, at al., 1 Debtors. Chapter 11 Case No (LSS) (Jointly Administered) Hearing Date: April 19, 2017 at 9:00 a.m. Objections Due: April 12, 2017 at 4:00 p.m. CERTIFICATE OF SERVICE I, Cory P. Stephenson, Esquire, certify that on April 12, 2017, I caused a true and correct copy of the COR Route 5 Company, LLC s Objection to the Cure Amount Listed in Debtors Notice of (I) Possible Treatment of Executory Contracts and Leases, (II) Fixing of Cure Amounts and (III) Deadline to Object [D.I. No. 272] to be served via the CM/ECF electronic notification system and first class mail upon the parties listed in the attached service list. BIELLI & KLAUDER, LLC Dated: April 12, 2017 By: /s/ Cory P. Stephenson Cory P. Stephenson (No. 6097) 1 The Debtors and the last four digits of their respective federal taxpayer identification numbers, where applicable, are as follows: Eastern Outfitters, LLC (9164); Subortis Retail Financing, LLC (9065); Eastern Mountain Sports, LLC (9553); Subortis IP Holdings, LLC, Bob s Stores, LLC (4389); and Bob s/ems Gift Card, LLC (9618). The Debtors executive headquarters are located at 160 Corporate Court, Meriden, CT

5 Case LSS Doc Filed 04/12/17 Page 1 of 1 SERVICE LIST Eastern Outfitters, LLC Attm: Daniel Bliss 160 Corporate Court Meriden, CT Mark E. Dendinger, Esq. Bracewell LLP CityPlace I, 34th Floor 185 Asylum Street Hartford, CT Robert G. Burns, Esq. Jennifer Feldsher, Esq. Bracewell LLP 1251 Avenue of Americas, 49th Floor New York, NY Jean M. Leamy, Esq. Office of the United States Trustee 844 King Street, Room 2207 Norman L. Pernick, Esq. Marion M. Quirk, Esq. Katharina Earle, Esq. Cole Schotz PC 500 Delaware Avenue, Suite 1410 Steven K. Kortanek, Esq. Drinker Biddle & Reath LLP 222 Delaware Avenue, Suite 1410 Alexander W. Stevenson Lincoln Partners Advisors, LLC 633 West Fifth Street, Suite 6650 Los Angeles, CA Jay R. Indyke, Esq. Richelle Kalnit, Esq. Cooley LLP 1114 Avenues of the Americas New York, NY Robert K. Malone, Esq. Drinker Biddle & Reath LLP 600 Campus Drive Forham Park, NJ Nancy A. Mitchell, Esq. Greenberg Traurig, LLP 200 Park Avenue New York, NY Karen G. Bifferato, Esq. Connolly Gallahger LLP 1000 West Street, Suite 1400