Case KG Doc 404 Filed 11/25/15 Page 1 of 10 UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE. Chapter 11

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1 Case KG Doc 404 Filed 11/25/15 Page 1 of 10 UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: CITY SPORTS, INC., et al., Chapter 11 Case No (KG) Debtors. 1 Jointly Administered DEBTORS MOTION FOR ENTRY OF ORDER ESTABLISHING PROCEDURES FOR THE ALLOWANCE, SETTLEMENT, AND PAYMENT OF 503(b)(9) CLAIMS FROM THE 503(b)(9) RESERVE City Sports, Inc. and City Sports-DC, LLC, as debtors and debtors in possession in the above-captioned Chapter 11 cases (together, the Debtors ), hereby file this motion (the Motion ) for entry of an order, substantially in the form attached hereto as Exhibit A (the Proposed Order ), pursuant to sections 105(a), 502, 503, and 363(b) of the United States Code (the Bankruptcy Code ) and Rules 9019(b) of the Federal Rules of Bankruptcy Procedure (as amended, the Bankruptcy Rules ), authorizing and approving procedures (the 503(b)(9) Procedures ) for the allowance, settlement and payment of claims arising under section 503(b)(9) of the Bankruptcy Code (the 503(b)(9) Claims ) from the 503(b)(9) Reserve (as defined below), including the release of Avoidance Actions (as defined below) pursuant to the 503(b)(9) Procedures. In support of the Motion, the Debtors respectfully represent as follows: JURISDICTION AND VENUE Objection Deadline: December 10, 2015 at 4:00 p.m. (ET) Hearing Date: December 17, 2015 at 3:00 p.m. (ET) 1. This Court has jurisdiction to consider the Motion pursuant to 28 U.S.C. 157 and This is a core proceeding pursuant to 28 U.S.C. 157(b). Venue of these cases and 1 The Debtors in these Chapter 11 cases, together with the last four digits of each Debtor s federal tax identification number, are as follows: City Sports, Inc. (6205); and City Sports-DC, LLC (6205). The mailing address for the Debtors, solely for purposes of notices and communications, is: 77 N. Washington Street, Boston, MA EAST\

2 Case KG Doc 404 Filed 11/25/15 Page 2 of 10 this Motion in this District is proper pursuant to 28 U.S.C and The statutory predicates for the relief requested herein are sections 105(a), 363(b), 502, and 503 of the Bankruptcy Code, and Bankruptcy Rule 9019(b). BACKGROUND 2. On October 5, 2015 (the Petition Date ), the Debtors commenced these bankruptcy cases (the Chapter 11 Cases ) by filing voluntary petitions for relief under Chapter 11 of the Bankruptcy Code. The Debtors continue to manage and operate their businesses as debtors in possession pursuant to sections 1107 and 1108 of the Bankruptcy Code. 3. On October 15, 2015, an official committee of unsecured creditors the ( Committee ) was appointed in these Chapter 11 Cases. As of the date hereof, no trustee or examiner has been appointed in these Chapter 11 Cases. These Chapter 11 Cases are jointly administered for procedural purposes only. 4. The factual background regarding the Debtors, including their business operations, their capital and debt structures, and the events leading to the filing of these Chapter 11 Cases, is set forth in detail in the Declaration of Andrew W. Almquist in Support of Chapter 11 Petitions and First Day Motions (the First Day Declaration ) [Docket No. 15]. 5. On November 13, 2015, the Court entered the Final Order (I) Authorizing Use Of Cash Collateral, (II) Granting Adequate Protection, and (III) Modifying The Automatic Stay (the Final Cash Collateral Order ) [Docket No. 330] which provided that, among other things, $625,000 to be held in reserve for the payment of 503(b)(9) Claim (the 503(b)(9) Reserve ). RELIEF REQUESTED 6. In the interest of expediting the process for paying 503(b)(9) Claims and reducing the administrative and financial burden imposed on the Court and the Debtors estates associated with individual motions filed by creditors holding 503(b)(9) Claims, the Debtors request entry of EAST\

3 Case KG Doc 404 Filed 11/25/15 Page 3 of 10 an order, substantially in the form as the Proposed Order, approving procedures for allowance, settlement and payment of 503(b)(9) Claims from the 503(b)(9) Reserve. The proposed 503(b)(9) Procedures set forth herein are designed to allow claimants holding 503(b)(9) Claims (the Claimants ) to participate in a pro rata distribution from the 503(b)(9) Reserve, which based on the Debtors books and records, is expected to be 25% (the Pro Rata Distribution ), and to the extent additional funds are available for distribution after all other administrative and priority claims are satisfied, the Claimants will receive additional distributions. As described below, the Pro Rata Distribution may be made in two installments. 7. Claimants are urged to submit the Expense Request (as defined below) and an executed Settlement Agreement (as defined below) as soon as possible and even prior to the approval of the Proposed Order because in the event such order is approved, the Debtors will be authorized to make an initial distribution to Claimants of 20% of the undisputed portion of the 503(b)(9) Claim on or prior to December 31, A second distribution on the 503(b)(9) Claim will occur within 45 days of the Deadline (as defined below). 8. Pursuant to the Settlement Agreement (as defined below), the Debtors will waive and release any and all claims and causes of action arising under Chapter 5 of the Bankruptcy Code (the Avoidance Actions ) that they have or may have against the Claimant. 9. In the event the Court does not approve this Motion, the Debtors will treat the Expense Request as a request for administrative payment and the Settlement Agreement will be null and void. EAST\

4 Case KG Doc 404 Filed 11/25/15 Page 4 of Claimants who do not wish to submit an Expense Request (as defined below) pursuant to the 503(b)(9) Procedures and participate in the distribution from the 503(b)(9) Reserve may still pursue their 503(b)(9) Claim and may receive a distribution pursuant to a chapter 11 plan or a separate order of the Court if there are sufficient funds to pay such 503(b)(9) Claims. THE 503(b)(9) PROCEDURES 11. The Debtors believe that it would be more efficient and cost effective for their estates and creditors if they were authorized to allow, settle and pay undisputed 503(b)(9) Claims pursuant to the proposed 503(b)(9) Procedures set forth below. 12. If the Debtors are so authorized, their estates will be spared not only the expense, delay, and uncertainty that otherwise would be associated with the unnecessary administrative costs attendant to drafting, serving, and filing dozens of pleadings, but also the fees incurred by attorneys for Court appearances related to separate motions with respect to each 503(b)(9) Claim. 13. In light of the foregoing, and in an attempt to reduce the administrative burden imposed on the Debtors and their estates, the Debtors propose the following 503(b)(9) Procedures for the allowance, settlement and payment of 503(b)(9) Claims from the 503(b)(9) Reserve: a. Claimants must submit a 503(b)(9) administrative expense request (the Expense Request ), attached to the Proposed Order as Exhibit 1, together with supporting documentation including but not limited to statements, invoices and/or contracts with respect to goods received by the Debtors on or after September 15, b. Claimants must also submit a settlement and release agreement, substantially in the form attached to the Proposed Order as Exhibit 2 (each, a Settlement Agreement ). The Settlement Agreement may not be changed in a manner that impacts the release of Wells Fargo Bank, National Association (the Lender ) without the Lender s written consent. EAST\

5 Case KG Doc 404 Filed 11/25/15 Page 5 of 10 c. The Expense Request and the Settlement Agreement (together, the Forms ) must be signed and submitted to the Debtors claims agent ( Rust Omni ) so as to be received by Rust Omni no later than January 15, 2016 at 4:00 p.m. (Eastern Time) (the Deadline ). d. The Forms may be submitted to Rust Omni by -or- Mail: City Sports, Inc. et al. c/o Rust Consulting Omni Bankruptcy 5955 De Soto Avenue, Suite 100 Woodland Hills, CA e. Upon receipt of the Forms and the entry of an order approving the Motion, the Debtors will be authorized, without a further court order, to make an initial distribution of 20% of the undisputed portion of a 503(b)(9) Claim (the Allowed 503(b)(9) Claims ) from the 503(b)(9) Reserve prior to the Deadline. f. Within 45 days of the Deadline, the Debtors will be authorized, without a further court order, to make a second distribution on the Allowed 503(b)(9) Claim, such that together with the first distribution, the total distribution is approximately 25% of the Allowed 503(b)(9) Claim. To the extent additional funds are available for distribution after all other administrative and priority claims are satisfied, Claimants are eligible to receive additional distributions up to the amount of their respective Allowed 503(b)(9) Claim. g. For the avoidance of doubt, to the extent there is a dispute with respect to any portion of a 503(b)(9) Claim asserted by a Claimant that is not resolved consensually, the Debtors will be authorized to pay the pro rata distribution of the undisputed amount of the asserted 503(b)(9) Claim to such Claimant. h. Each Claimant who enters into a Settlement Agreement and is paid pursuant to the terms thereof will waive any objections, including but not limited to objections on grounds that the Claimant did not receive payment in full of its 503(b)(9) Claim, to any chapter 11 plan or any motion to dismiss that may be filed by the Debtors in these Chapter 11 Cases. EAST\

6 Case KG Doc 404 Filed 11/25/15 Page 6 of 10 BASIS FOR RELIEF 14. A key component of the settlement between the Debtors, Committee and Wells Fargo Bank, National Association (the Lender ) in connection with the Final Cash Collateral Order, was the establishment of the 503(b)(9) Reserve and that a portion of the 503(b)(9) Claims will be paid on an expedited basis. In exchange for payment of a portion of the 503(b)(9) Claims and a release by the Debtors and their estates of Avoidance Actions against a Claimant, the Claimant will not object on any grounds whatsoever, including, but not limited to that its 503(b)(9) Claim was not paid in full, to any chapter 11 plan or any motion to dismiss that may be filed by the Debtors in these Chapter 11 Cases. 15. Section 503(b) of the Bankruptcy Code provides that an administrative expense of the estate includes the value of goods received by the debtor within 20 days before the date of commencement of a case under this title in which the goods have been sold to the debtor in the ordinary course of such debtor s business. 11 U.S.C. 503(b)(9). Accordingly, the Debtors may pay claims arising under section 503(b)(9) of the Bankruptcy Code as an administrative expense in the ordinary course of business. 16. Moreover, to the extent the payment is considered outside of the ordinary course, under section 363(b) of the Bankruptcy Code, after notice and a hearing, a bankruptcy court may authorize a Chapter 11 debtor to use property of the estate other than in the ordinary course of business. Under the same section, a court should authorize non-ordinary course business transactions where the debtor has articulated a valid business justification for the requested use of estate assets. See In re Ionosphere Clubs, Inc., 98 B.R., 174, 175 (Bankr. S.D.N.Y. 1989) (section 363(b) gives the court broad flexibility to make payments outside of ordinary course of business as long as the debtor articulates a business justification); In re Cont'l Air Lines, Inc., EAST\

7 Case KG Doc 404 Filed 11/25/15 Page 7 of F.2d 1223, 1226 (5th Cir. 1986) ( there must be some articulated business justification for using, selling, or leasing the property outside the ordinary course of business. ). 17. The Debtors believe, in their reasonable business judgment, that the 503(b)(9) Procedures constitute a cost-effective method for settling and paying the 503(b)(9) Claims and avoids the expense and risk inherent in litigating those claims. Given the number of claims that the Debtors believe can be settled for relatively moderate amounts compared with the overall value of the Debtors estates, filing individual pleadings for each proposed settlement, noticing each compromise and settlement to each of the dozens of parties on the master service list on file with the Court, and conducting individual hearings would be an expensive, cumbersome, and highly inefficient way to resolve many of the 503(b)(9) Claims. 18. The Debtors submit that the 503(b)(9) Procedures are an appropriate use of the Court s power under Bankruptcy Rule 9019(b). Bankruptcy Rule 9019(b) permits a Court, after a hearing on such notice as the Court may direct, to fix a class or classes of controversies and authorize the trustee to compromise or settle controversies within such class or classes without further hearing or notice. Fed. R. Bankr. P. 9019(b). 19. Rule 9019 empowers Bankruptcy Courts to approve settlements if they are in the best interests of the estate. In re Drexel Burnham Lambert Group, Inc., 134 B.R. 499, 505 (Bankr. S.D.N.Y. 1991); see In re Charles St., Inc., 209 B.R. 618, 620 (S.D.N.Y. 1997); In re Ionosphere Clubs, Inc., 156 B.R. 414, 426 (S.D.N.Y. 1993), aff d, 17 F.3d 600 (2d Cir. 1994). The settlement need not result in the best possible outcome for the debtor, but must not fall below the lowest point in the range of reasonableness. Drexel Burnham Lambert Group, 134 B.R. at 505 (internal citations omitted); see also In re W.T. Grant Co., 699 F.2d 599, 608 (2d Cir. 1983). EAST\

8 Case KG Doc 404 Filed 11/25/15 Page 8 of The Debtors will continue to exercise their reasonable business judgment in negotiating compromises and settlements and will continue to be guided by the factors relevant to a determination of the reasonableness of such settlements, including: a) the probability of success in the litigation; b) the complexity, expense, and likely duration of the litigation; c) all other factors relevant to making a full and fair assessment of the wisdom of the proposed compromise; and d) whether the proposed compromise is fair and equitable to the Debtors, their creditors, and other interested parties. See Protective Comm. for Indep. Stockholders of TMT Trailer Ferry, Inc. v. Anderson, 390 U.S. 414, 424 (1968). Basic to the process of evaluating proposed settlements is the need to compare the terms of the compromise with the likely rewards of litigation. Id. at Additionally, the Debtors submit that the settlements to be entered pursuant to the 503(b)(9) Procedures would meet the standards set forth in TMT Trailer. Specifically, the Debtors will not settle any claims unless the settlement is reasonable in the judgment of the Debtors upon consideration of all the relevant factors and is otherwise within the requirements of types of claims to be settled under the 503(b)(9) Procedures. 22. In view of the foregoing, the Debtors submit that implementation of the 503(b)(9) Procedures is fair and in the best interests of the Debtors and all other parties in interest. 23. The Creditors Committee has advised the Debtors that it supports the relief requested herein. 24. The Debtors reserve the right, in consultation with the Committee, to seek modification of the 503(b)(9) Procedures as they deem appropriate. EAST\

9 Case KG Doc 404 Filed 11/25/15 Page 9 of 10 NOTICE 25. Notice of this Motion has been given to: (a) counsel to Wells Fargo Bank, N.A., (i) Riemer & Braunstein, Three Center Plaza, 6th Floor, Boston, MA 02110, Attn: David S. Berman, Esq.; and (ii) Womble Carlyle Sandridge & Rice, LLP, 222 Delaware Avenue, Suite 1501, Wilmington, DE 19801, Attn: Steven K. Kortanek, Esq., (b) counsel to the Committee, (i) Cooley, LLP, 1114 Avenue of the Americas, New York, NY 10036, Attn: Jeffrey L. Cohen, Esq,. and Jay Indyke, Esq.; and (ii) The Rosner Law Group LLC, 824 N. Market Street, Suite 810, Wilmington, DE 19801, Attn: Julia B. Klein, Esq., (c) Office of the United States Trustee, J. Caleb Boggs Federal Building, 844 King Street, Suite 2207, Lockbox 35, Wilmington, DE 19801, Attn: Mark Kenney, Esq. and Hannah McCollum, Esq. (d) the Internal Revenue Service; (e) the United States Attorney for the District of Delaware; (f) the known Claimants who hold 503(b)(9) Claims; and (g) any such other party entitled to notice pursuant to Bankruptcy Rule 2002 and Local Rule (b). The Debtors submit that no other or further notice need be given. 26. No previous request for the relief sought herein has been made by the Debtors to this or any other Court. [Remainder of page left intentionally blank.] EAST\

10 Case KG Doc 404 Filed 11/25/15 Page 10 of 10 WHEREFORE the Debtors respectfully request entry of an order, substantially in the form attached hereto as Exhibit A, granting the relief requested herein and such other and further relief as is just. Dated: November 25, 2015 Wilmington, Delaware Respectfully submitted, DLA PIPER LLP (US) /s/ Kaitlin M. Edelman Kaitlin M. Edelman (DE 5924) 1201 North Market Street, Suite 2100 Wilmington, Delaware Telephone: (302) Facsimile: (302) and- Gregg M. Galardi (DE 2991; NY ) Dienna Corrado (admitted pro hac vice) DLA Piper LLP (US) 1251 Avenue of the Americas New York, New York Telephone: (212) Facsimile: (212) Counsel to Debtors and Debtors in Possession EAST\

11 Case KG Doc Filed 11/25/15 Page 1 of 12 EXHIBIT A Proposed Order EAST\

12 Case KG Doc Filed 11/25/15 Page 2 of 12 UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: CITY SPORTS, INC., et al., Chapter 11 Case No (KG) Debtors. 1 Jointly Administered Related Docket No: ORDER ESTABLISHING PROCEDURES FOR THE ALLOWANCE, SETTLEMENT, AND PAYMENT OF 503(b)(9) CLAIMS FROM THE 503(b)(9) RESERVE Upon the motion (the Motion ) 2 of the Debtors for entry of an order, pursuant to sections 105(a), 363(b), 502, and 503(b)(9) of title 11 of the United States Code (the Bankruptcy Code ) and Rule 9019(b) of the Federal Rules of Bankruptcy Procedure (as amended, the Bankruptcy Rules ), for entry of an order authorizing and approving procedures (the 503(b)((9) Procedures ) for the allowance, settlement and payment of claims arising under section 503(b)(9) of the Bankruptcy Code (the 503(b)(9) Claims ) from the 503(b)(9) Reserve (as defined in the Motion) as more fully set forth in the Motion; and the Court having jurisdiction to consider the Motion and the relief requested therein pursuant to 28 U.S.C. 1334; and consideration of the Motion and the relief requested therein being a core proceeding pursuant to 28 U.S.C. 157(b); and venue being proper in this district pursuant to 28 U.S.C and 1409; and due and sufficient notice of the Motion having been given under the particular circumstances; and it appearing that no other or further notice is necessary; and it appearing that the relief requested in the Motion is in the best interests of the Debtors, their estates, their 1 The Debtors in these Chapter 11 cases, together with the last four digits of each Debtor s federal tax identification number, are as follows: City Sports, Inc.. (6205); and City Sports-DC, LLC (6205). The mailing address for the Debtors, solely for purposes of notices and communications, is: 77 N. Washington Street, Boston, MA Capitalized terms used but not defined herein shall have the meanings ascribed to such terms in the Motion or the First Day Declaration. EAST\

13 Case KG Doc Filed 11/25/15 Page 3 of 12 creditors, and other parties in interest; and the Court having determined that the legal and factual bases set forth in the Motion establish just cause for the relief granted herein; and upon all the proceedings had before the Court; and after due deliberation thereon; and good and sufficient cause appearing therefor, IT IS HEREBY ORDERED THAT: The Motion is GRANTED as set forth herein. Within two (2) business days after entry of this Order, the Debtors will cause to have this Order, together with the Expense Request and the Settlement Agreement, served by first class mail on all of the Debtors known trade vendors that provide goods to the Debtors. 3. The Debtors are authorized to settle claims in accordance with the following 503(b)(9) Procedures: a. Claimants must submit a 503(b)(9) administrative expense request (the Expense Request ), attached to hereto as Exhibit 1, together with supporting documentation including but not limited to statements, invoices and/or contracts with respect to goods received by the Debtors on or after September 15, b. Claimants must also submit a settlement and release agreement, substantially in the form attached hereto as Exhibit 2 (each, a Settlement Agreement ). The Settlement Agreement may not be changed in a manner that impacts the release of Wells Fargo Bank, National Association (the Lender ) without the Lender s written consent. c. The Expense Request and the Settlement Agreement (together, the Forms ) must be signed and submitted to the Debtors claims agent ( Rust Omni ) so as to be received by Rust Omni no later than January 15, 2016 at 4:00 p.m. (Eastern Time) (the Deadline ). EAST\

14 Case KG Doc Filed 11/25/15 Page 4 of 12 d. The Forms may be submitted to Rust Omni by -or- Mail: City Sports, Inc. et al. c/o Rust Consulting Omni Bankruptcy 5955 De Soto Avenue, Suite 100 Woodland Hills, CA e. Upon receipt of the Forms and the entry of this Order, the Debtors will be authorized, without a further court order, to make an initial distribution of 20% of the undisputed portion of a 503(b)(9) Claim (the Allowed 503(b)(9) Claims ) from the 503(b)(9) Reserve prior to the Deadline. f. Within 45 days of the Deadline, the Debtors will be authorized, without a further court order, to make a second distribution on the Allowed 503(b)(9) Claim, such that together with the first distribution, the total distribution is approximately 25% of the Allowed 503(b)(9) Claim. To the extent additional funds are available for distribution after all other administrative and priority claims are satisfied, Claimants are eligible to receive additional distributions up to the amount of their respective Allowed 503(b)(9) Claim. g. For the avoidance of doubt, to the extent there is a dispute with respect to any portion of a 503(b)(9) Claim asserted by a Claimant that is not resolved consensually, the Debtors will be authorized to pay the pro rata distribution of the undisputed amount of the asserted 503(b)(9) Claim to such Claimant. h. Each Claimant who enters into a Settlement Agreement and is paid pursuant to the terms thereof will waive any objections, including but not limited to objections on grounds that the Claimant did not receive payment in full of its 503(b)(9) Claim, to any chapter 11 plan or any motion to dismiss that may be filed by the Debtors in these Chapter 11 Cases. 4. The Debtors are authorized to take any and all steps that are necessary and appropriate to settle and pay the 503(b)(9) Claims in accordance with the 503(b)(9) Procedures. 5. Claimants who do not submit a claim pursuant to the 503(b)(9) Procedures to participate in the distribution from the 503(b)(9) at this stage of the Chapter 11 Cases are not EAST\

15 Case KG Doc Filed 11/25/15 Page 5 of 12 barred from receiving a distribution pursuant to a chapter 11 plan or a separate order of the Court. 6. Any party who has questions regarding the 503(b)(9) Procedures may contact counsel to the Committee: Cooley LLP 1114 Avenue of the Americas New York, New York Jay R. Indyke, Esq. Jeffrey L. Cohen, Esq. Richelle Kalnit, Esq. Telephone: (212) Nothing in this Order shall constitute an admission of the validity, nature, amount, or priority of any claim asserted in these chapter 11 cases. 8. Entry of this Order is without prejudice to the Debtors rights to seek entry of an order modifying or supplementing the relief granted herein. 9. The terms and conditions of this Order shall be immediately effective and enforceable upon its entry. 10. This Court shall retain jurisdiction with respect to all matters arising from or related to the implementation, interpretation, or enforcement of this Order. Dated: November, 2015 Wilmington, Delaware THE HONORABLE KEVIN GROSS UNITED STATES BANKRUPTCY JUDGE EAST\

16 Case KG Doc Filed 11/25/15 Page 6 of 12 EXHIBIT 1 503(B)(9) ADMINISTRATION EXPENSE REQUEST FORM EAST\

17 Name of Debtor: UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE Name of Creditor (The person or other entity to whom the debtor owes money or property): Name and address where notices should be sent: 1. Section 503(b)(9) Expense Request Amount SECTION 503(b)(9) ADMINISTRATIVE EXPENSE REQUEST City Sports, Inc., et al. Case Number: Name: Address 1: Address 2: Address 3: Address 4: Address 5: Phone: Name and address where payment should be sent (if different from above): Name: Address 1: Address 2: Address 3: Address 4: Address 5: Phone: Check box to indicate that this administrative expense request amends a previously filed request. Court Claim Number: (If known) Filed On: Check this box if you are aware that anyone else has filed an administrative expense request relating to your request. Attach a copy of statement giving particulars. Carefully read instructions included with this Administrative Expense Request before completing. In order to have your request considered for payment and/or voting purposes, complete ALL applicable questions. Please submit your completed Section 503(b)(9) expense request form to: City Sports, Inc., et al, c/o Rust Omni, 5955 De Soto Avenue, Suite 100, Woodland Hills, CA or by to: Amount of Expenses: Date Incurred: $ Case KG Doc Filed 11/25/15 Page 7 of 12. THIS SPACE IS FOR COURT USE ONLY THIS SPACE IS FOR COURT USE ONLY Check this box if administrative expense request includes interest or other charges in addition to the principal amount of expense request. Attach itemized statement of interest or charges. 2. Basis for Section 503(b)(9) Administrative Expense Request 3. Last four digits of any number by which creditor identifies debtor: 4. Credits: 5. Documents: The amount of all payments on these expenses has been credited for the purpose of making this administrative expense request. Attach copies of any documents that support this request, such as purchase orders, invoices, itemized statements of running accounts, or contracts. You may also attach a summary. DO NOT SEND ORIGINAL DOCUMENTS. ATTACHED DOCUMENTS MAY BE DESTROYED AFTER SCANNING. If the documents are not available, please explain: Signature: The person filing this administrative expense request must sign it. Sign and print name and title, if any, of the creditor or other person authorized to file this request and state address and telephone number if different from the notice address above. Attach copy of power of attorney, if any. Date Signature Printed Name Title Penalty for presenting fraudulent claim: Fine of up to $500,000 or imprisonment for up to 5 years, or both. 18 U.S.C. 152 and

18 Case KG Doc Filed 11/25/15 Page 8 of 12 INSTRUCTIONS FOR ADMINISTRATIVE EXPENSE REQUEST The instructions and definitions below are general explanations of the law. In certain circumstances, such as bankruptcy cases that are not filed voluntarily by a debtor, exceptions to these general rules may apply. Court, Name of Debtor, and Case Number: Fill in the federal judicial district where the bankruptcy case was filed (for example, Central District of California), the debtor's full name, and the case number. If the creditor received a notice of the case from the bankruptcy court, all of this information is at the top of the notice. Creditor's Name and Address: Fill in the name of the person or entity asserting an administrative expense request and the name and address of the person who should receive notices issued during the bankruptcy case. A separate space is provided for the payment address if it differs from the notice address. The creditor has a continuing obligation to keep the court informed of its current address. See Federal Rule of Bankruptcy Procedure (FRBP) 2002 (g). 1. Section 503(b)(9) Expense Amount: State the total amount owed to the creditor on the date of the Bankruptcy filing. Check the box if interest or other charges are included in the Administrative Expense Request. 2. Basis for Section 503(b)(9) Expense Request: State the type of debt or how it was incurred. Examples include goods sold, money loaned, services performed, personal injury/wrongful death, car loan, mortgage note, and credit card If the expenses are based on the delivery of health care goods or services, limit the disclosure of the goods or services so as to avoid embarrassment or the disclosure of confidential health care information. You may be required to provide additional disclosure if an interested party objects to the request. 3. Last Four Digits of Any Number by Which Creditor Identifies Debtor: Items to be completed in Administrative Expense Request (if not already filled in) State only the last four digits of the debtor's account or other number used by the creditor to identify the debtor. 4. Credits: An authorized signature on this administrative expense request serves as an acknowledgment that when calculating the amount of the expenses, the creditor gave the debtor credit for any payments received toward the debt. 5. Documents: Attach copies of any documents or contracts that show the debt exists and a lien secures the debt. You may also attach a summary in addition to the documents themselves. FRBP 3001(c) and (d). If the expenses are based on the delivering health care goods or services, limit disclosing confidential health care information. Do not send original documents, as attachments may be destroyed after scanning. Date and Signature: The individual completing this administrative expense request must sign and date it. If you sign this form, you declare under penalty of perjury that the information provided is true and correct to the best of your knowledge, information, and reasonable belief. Your signature is also a certification that the request meets the requirements of FRBP 9011(b). Whether the administrative expense request is filed electronically or in person, if your name is on the signature line, you are responsible for the declaration. Print the name and title, if any, of the creditor or other person authorized to file this administrative expense request. State the filer's address and telephone number if it differs from the address given on the top of the form for purposes of receiving notices. If the administrative expense request is filed by an authorized agent, provide both the name of the individual filing the request and the name of the agent. If the authorized agent is a servicer, identify the corporate servicer as the company. Criminal penalties apply for making a false statement on an administrative expense request. --- DEFINITIONS INFORMATION --- Debtor A debtor is the person, corporation, or other entity that has filed a bankruptcy case. Creditor A creditor is a person, corporation, or other entity to whom debtor owes a debt that was incurred before the date of the bankruptcy filing. See 11 U.S.C. 101 (10). Acknowledgment of Filing of Administrative Expense Request To receive acknowledgment of your filing, you may either enclose a stamped self-addressed envelope and a copy of this administrative expense request or you may access the court's PACER system ( for a small fee to view your filed administrative expense request.

19 Case KG Doc Filed 11/25/15 Page 9 of 12 EXHIBIT 2 FORM OF SETTLEMENT AGREEMENT EAST\

20 Case KG Doc Filed 11/25/15 Page 10 of 12 SETTLEMENT AGREEMENT This settlement agreement (the Settlement Agreement ) is entered into as of December, 2015 by and among City Sports, Inc. and City Sports-DC, LLC 1 ( City Sports or the Debtors ), on the one hand, and (the Claimant ), on the other hand (collectively, the Parties ). RECITALS: A. On October 5, 2015, City Sports and certain of its subsidiaries commenced voluntary cases under chapter 11 of title 11 of the United States Code (the Bankruptcy Code ) before the United States Bankruptcy Court for the District of Delaware (the Court ), Case No (KG). The chapter 11 cases have been consolidated for procedural purposes only and are being jointly administered pursuant to Bankruptcy Rule 1015(b). B. On November 13, 2015, the Court entered the Final Order (I) Authorizing Use Of Cash Collateral, (II) Granting Adequate Protection, and (III) Modifying The Automatic Stay (the Final Cash Collateral Order ) [Docket No. 330]. C. The Claimant asserts that the 503(b)(9) Claim is $ (the 503(b)(9) Claim ). D. On November 25, 2015, the Debtors filed the Debtors Motion for Entry of an Order Establishing Procedures For the Allowance, Settlement, and Payment of 503(b)(9) Claims From the 503(b)(9) Reserve (the Motion ). E. After good-faith, arms -length negotiations, the Parties have agreed to resolve the 503(b)(9) Claim pursuant to the terms and conditions set forth in this Settlement Agreement. AGREEMENT: NOW, THEREFORE, in consideration of the foregoing, it is hereby stipulated and agreed that: 1. The Recitals set forth above form an integral part of this Settlement Agreement and are incorporated fully herein. 2. Subject to entry of an order approving the Motion, this Settlement Agreement shall become effective upon execution by the Claimant (the Effective Date ). 1 The Debtors in these Chapter 11 cases, together with the last four digits of each Debtor s federal tax identification number, are as follows: City Sports, Inc. (6205); and City Sports-DC, LLC (6205). The mailing address for the Debtors, solely for purposes of notices and communications, is: 77 N. Washington Street, Boston, MA EAST\

21 Case KG Doc Filed 11/25/15 Page 11 of The 503(b)(9) Claim is reduced and allowed against City Sports in the amount of $[ ] (the Allowed Claim ) and shall by paid by the Debtors no later than ten (10) business days following the Effective Date pursuant to the instructions below: By Check: Payable to: Address: By Wire Transfer: 4. The Claimant agrees that it will not object on any grounds, including, but not limited to, that the Allowed 503(b)(9) Claim has not been paid in full, to any chapter 11 plan or any type of motion to dismiss that may be filed by the Debtors in the Chapter 11 Cases. 5. Other than the right to receive payments or distributions on account of the Allowed Claim, the Claimant and its affiliates, successors and assigns, and its past, present and future members, officers, directors, partners, principals, agents, insurers, servants, employees, representatives, administrators, executors, trustees and attorneys (collectively, the Claimant Parties ), shall have no further right to payment from City Sports, Inc. or City Sports-DC, LLC, Wells Fargo Bank, National Association, or their respective successors or assigns (collectively, the Released Parties ) on account of any administrative claims, including any other claim arising under 503 of the Bankruptcy Code. 6. The Debtors and their bankruptcy estates hereby waive and release any and all claims and causes of action arising under Chapter 5 of the Bankruptcy Code (the Avoidance Actions ) that they have or may have against the Claimant. 7. This Settlement Agreement is only valid and binding upon the entry of an order approving the Motion. 8. This Settlement Agreement contains the entire agreement between the Parties as to the subject matter hereof and supersedes all prior agreements and undertakings between the Parties relating thereto. 9. This Settlement Agreement may not be modified other than by signed writing executed by the Parties hereto. 10. As of the date hereof, Claimant represents and warrants that it has authority to enter into this Settlement Agreement. EAST\

22 Case KG Doc Filed 11/25/15 Page 12 of Each person who executes this Settlement Agreement represents that he or she is duly authorized to do so on behalf of the respective Party hereto and that each such Party has full knowledge and has consented to this Settlement Agreement. 12. This Settlement Agreement may be executed in counterparts, each of which shall be deemed an original but all of which together shall constitute one and the same instrument, and it shall constitute sufficient proof of this Settlement Agreement to present any copy, copies, or facsimiles signed by the Parties hereto to be charged. 13. This Settlement Agreement shall inure to the benefit of, and shall be binding upon, the Parties hereto and their respective successors and assigns. 14. This Settlement Agreement shall be exclusively governed by and construed and enforced in accordance with the laws of the State of New York, without regard to conflicts of law principles thereof. The Court shall have exclusive jurisdiction over any and all disputes arising out of or otherwise relating to this Settlement Agreement. Should the Court abstain from exercising its jurisdiction or be found not to have jurisdiction over a matter relating to this Settlement Agreement, such matter shall be adjudicated in either a federal district court in the State of New York or a state court in the State of New York. THE UNDERSIGNED WARRANT THAT THEY HAVE READ THE TERMS OF THIS SETTLEMENT AGREEMENT, HAVE HAD THE ADVICE OF COUNSEL OR THE OPPORTUNITY TO OBTAIN SUCH ADVICE IN CONNECTION WITH READING, UNDERSTANDING AND EXECUTING THE SETTLEMENT AGREEMENT, AND HAVE FULL KNOWLEDGE OF THE TERMS, CONDITIONS AND EFFECTS OF THIS SETTLEMENT AGREEMENT. /s/ By: Print Name: Title: EAST\

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