Case MFW Doc 2204 Filed 12/20/20 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE. Debtors. Re: Docket No.

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RLF1 24495206v.1

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re

The Hertz Corporation, et al.,1

Debtors.

Chapter 11

Case No. 20-11218 (MFW) (Jointly Administered) Re: Docket No. 1458

CERTIFICATION OF COUNSEL REGARDING SECOND OMNIBUS ORDER APPROVING STIPULATIONS EXTENDING DEADLINE TO ASSUME OR REJECT

CERTAIN NON-RESIDENTIAL REAL PROPERTY LEASES UNDER SECTION 365(d)(4) OF THE BANKRUPTCY CODE

The undersigned hereby certifies as follows:

1. On October 8, 2020, the United States Bankruptcy Court for the District of Delaware (the “Bankruptcy Court”) entered an order [Docket No. 1458] extending the period within which The Hertz Corporation (“Hertz”) and its affiliated debtors in the above-captioned chapter 11 cases (the “Chapter 11 Cases”), as debtors and debtors in possession (collectively, the “Debtors”), must assume or reject unexpired leases of non-residential real property (the “Assumption/Rejection Period”) through and including December 21, 2020.

2. Each Lessee (as defined in each applicable Stipulation (as defined herein)) and each lessor (the “Lessors”)2 entered into a Stipulation Extending the Time Period Within Which the Debtors may Assume or Reject an Unexpired Lease of Non-Residential Real Property (each, a

1_{The last four digits of The Hertz Corporation’s tax identification number are 8568. The location of the} debtors’ service address is 8501 Williams Road, Estero, FL 33928. Due to the large number of debtors in these chapter 11 cases, which are jointly administered for procedural purposes, a complete list of the debtors and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the website of the debtors’ claims and noticing agent at https://restructuring.primeclerk.com/hertz.

2

The list of Lessors who have consented to extensions of the time period within which their Lease must be assumed or rejected is attached hereto as Exhibit 1.

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“Stipulation”), pursuant to which the time period within which each such Lessee must assume or reject each such Lease (as defined in each applicable Stipulation)3 is extended pursuant to the terms set forth therein.

3. Attached hereto as Exhibit 2 is proposed form of order (the “Proposed Order”) approving each of the Stipulations attached thereto as Exhibits A-1 – A-12. The form of Proposed Order has been circulated to the Office of the United States Trustee for the District of Delaware and the Committee, and the foregoing parties do not object to the entry of the Proposed Order.

WHEREFORE, the Debtors respectfully request that the Proposed Order be entered at the earliest convenience of the Bankruptcy Court.

[Remainder of Page Intentionally Left Blank]

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For the avoidance of doubt, nothing in any Stipulation shall be construed as an admission by any party or third party, including the Official Committee of Unsecured Creditors (the “Committee”), that any particular agreement between the applicable Lessor and the Lessees is a lease for non-residential real property.

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Dated: December 20, 2020 /s/ J. Zachary Noble

RICHARDS, LAYTON & FINGER, P.A. Mark D. Collins (No. 2981)

John H. Knight (No. 3848) Brett M. Haywood (No. 6166) Christopher M. De Lillo (No. 6355) J. Zachary Noble (No. 6689)

One Rodney Square 920 N. King Street Wilmington, DE 19801 Telephone: (302) 651-7700 Facsimile: (302) 651-7701 Collins@rlf.com Knight@rlf.com Haywood@rlf.com DeLillo@rlf.com Noble@rlf.com —and—

WHITE & CASE LLP

Thomas E Lauria (admitted pro hac vice) Matthew C. Brown (admitted pro hac vice) 200 South Biscayne Boulevard, Suite 4900 Miami, FL 33131

Telephone: (305) 371-2700 tlauria@whitecase.com

mbrown@whitecase.com

J. Christopher Shore (admitted pro hac vice) David M. Turetsky (admitted pro hac vice) Andrea Amulic (admitted pro hac vice) 1221 Avenue of the Americas

New York, NY 10020

Telephone: (212) 819-8200 cshore@whitecase.com

david.turetsky@whitecase.com andrea.amulic@whitecase.com

Jason N. Zakia (admitted pro hac vice) 111 South Wacker Drive

Chicago, IL 60606

Telephone: (312) 881-5400 jzakia@whitecase.com

Ronald K. Gorsich (admitted pro hac vice) Aaron Colodny (admitted pro hac vice) Andrew Mackintosh (admitted pro hac vice) Doah Kim (admitted pro hac vice)

555 South Flower Street, Suite 2700 Los Angeles, CA 90071 Telephone: (213) 620-7700 rgorsich@whitecase.com aaron.colodny@whitecase.com amackintosh@whitecase.com doah.kim@whitecase.com Co-Counsel to the Debtors and Debtors-in-Possession

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit 1 Lessors

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AMERICAS 105531464 RLF1 24495206v.1

LESSORS List of Lessors

City of Albuquerque; City of Austin, Texas; Akron Airport Authority; Eugene Airport; William P Hobby Airport-Houston; George Bush Intercontinental/Houston Airport; the County of Clark, a political subdivision of the State of Nevada; Los Angeles World Airports; Miami International Airport; Port of Portland International Airport; Port of Seattle; City of San Jose-Mineta San Jose International Airport.

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit 2 Proposed Order

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AMERICAS 105531464 RLF1 24495206v.1

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re

Debtors.

Chapter 11

Case No. 20-11218 (MFW) (Jointly Administered) Re: Docket No. 1458

SECOND OMNIBUS ORDER APPROVING STIPULATIONS EXTENDING DEADLINE TO ASSUME OR REJECT CERTAIN NON-RESIDENTIAL REAL PROPERTY

LEASES UNDER SECTION 365(d)(4) OF THE BANKRUPTCY CODE

Upon consideration of each stipulation, attached hereto as Exhibits A-1 – A-12 (each, a “Stipulation”), between each Lessee and each Lessor subject to each such Stipulation (collectively, the “Parties”), pursuant to section 365(d)(4) of the Bankruptcy Code, for authorization to extend the time to assume or reject each applicable Lease,2_{all as more fully set} forth in each Stipulation; and the Court having jurisdiction to consider each Stipulation and the relief requested therein pursuant to 28 U.S.C. §§ 157 and 1334; and consideration of each Stipulation and the requested relief being a core proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and the relief being in the best interests of the Debtors, their estates and their creditors; it is

1. Each Stipulation is hereby approved.

1_{The last four digits of The Hertz Corporation’s tax identification number are 8568. The location of the} debtors’ service address is 8501 Williams Road, Estero, FL 33928. Due to the large number of debtors in these chapter 11 cases, which are jointly administered for procedural purposes, a complete list of the debtors and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the website of the debtors’ claims and noticing agent at https://restructuring.primeclerk.com/hertz.

2_{Capitalized terms used herein and not otherwise defined shall have the meanings ascribed to them in each} Stipulation, as applicable.

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2. Each Stipulation shall become effective immediately upon entry of this Order. 3. This Court retains jurisdiction over all matters arising from or related to the implementation or interpretation of this Order.

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-1

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re

Debtors.

Chapter 11

Case No. 20-11218 (MFW) (Jointly Administered)

STIPULATION EXTENDING THE TIME PERIOD WITHIN WHICH THE DEBTORS MAY ASSUME OR REJECT AN UNEXPIRED LEASES OF

NON-RESIDENTIAL REAL PROPERTY

The Hertz Corporation and certain of its subsidiaries, debtors and debtors in possession in the above-captioned chapter 11 cases (together, the “Debtors”) hereby stipulate (the “Stipulation”) as follows:

RECITALS

WHEREAS, on May 22, 2020 (the “Petition Date ”), the Debtors each filed a voluntary petition in this Court for relief under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”). The Debtors’ chapter 11 cases are being jointly administered for procedural purposes only pursuant to an order of this Court [Docket No. 182];

WHEREAS, the Debtors continue to manage and operate their businesses as debtors in possession pursuant to sections 1107 and 1108 of the Bankruptcy Code;

WHEREAS, City of Albuquerque (the “Lessor”) and THE HERTZ CORPORATION AND/OR any of its applicable subsidiaries (the “Lessee,”) entered into agreements whereby the

1 The last four digits of The Hertz Corporation’s tax identification number are 8568. The location of the debtors’ service address is 8501 Williams Road, Estero, FL 33928. Due to the large number of debtors in these chapter 11 cases, which are jointly administered for procedural purposes, a complete list of the debtors and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the website of the Debtors’ claims and noticing agent at https://restructuring.primeclerk.com/hertz.

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Lessor agreed to leases to the Lessee certain non-residential real property located at ABQ, to be used in connection with the Debtors’ operations (the “Leases”);2

WHEREAS, on October 8, 2020, the United States Bankruptcy Court for the District of Delaware (the “Bankruptcy Court”) entered that certain Order Extending Time to Assume or Reject Unexpired Leases of Non-Residential Real Property [D.I. 1458], thereby extending the period within which the Debtors must assume or reject unexpired leases of non-residential real property to and through December 21, 2020;

WHEREAS, the Lessee has requested, and the Lessor has agreed to grant Lessee, additional time to assume or reject the Leases as permitted under section 365(d)(4)(B)(ii) of the Bankruptcy Code; and

WHEREAS, the Parties desire to memorialize their agreement in this Stipulation. AGREEMENT

1. The foregoing Recitals are true and correct and are incorporated herein by reference.

2. Pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code, the time period during which the Debtors may assume or reject the Leases is hereby extended through and including the earlier of (a) the effective date of a chapter 11 plan for the Debtors and (b) March 22, 2021 (the “Extension Date”) without prejudice to the right of the Debtors to assume or reject the Leases prior to the Extension Date, or to request additional extensions of time within which to assume or reject the Leases pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code.

3. This Stipulation shall be immediately effective and enforceable upon its entry and shall be binding upon (a) the Debtors; (b) any liquidating trustee, plan trustee, plan administrator,

2_{Nothing herein shall be construed as an admission by the Debtors that any of their agreements with the Lessor are}

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distribution agent and/or any other responsible person appointed pursuant to any chapter 11 plan confirmed in these cases; (c) any chapter 11 trustee appointed in these cases; and/or (d) any chapter 7 trustee appointed or elected in these cases.

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In witness whereof, the Parties have caused this Stipulation to be executed in counterparts, all as of the date hereof.

Dated: December 18, 2020 Lessee

By: _______________ WHITE & CASE LLP Ronald K. Gorsich rgorsich@whitecase.com Counsel to the Debtors and Debtors-in-Possession Lessor

By: /s/ Shay Elizabeth Meagle_______ MOSES, DUNN, FARMER &

TUTHILL, P.C Shay Elizabeth Meagle shay@moseslaw.com

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-2

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AMERICAS 105408605

Debtors.

Chapter 11

RECITALS

WHEREAS, on May 22, 2020 (the “Petition Date”), the Debtors each filed a voluntary petition in this Court for relief under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”). The Debtors’ chapter 11 cases are being jointly administered for procedural purposes only pursuant to an order of this Court [Docket No. 182];

WHEREAS, the City of Austin, Texas (the “Lessor”) and The Hertz Corporation (the “Lessee,”) are party to certain agreements whereby the Lessor has authorized Lessee to operate at

1 _{The last four digits of The Hertz Corporation’s tax identification number are 8568. The location of the} debtors’ service address is 8501 Williams Road, Estero, FL 33928. Due to the large number of debtors in these chapter 11 cases, which are jointly administered for procedural purposes, a complete list of the debtors and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the website of the Debtors’ claims and noticing agent at https://restructuring.primeclerk.com/hertz.

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and utilize certain designated space at Austin-Bergstrom International Airport in connection with the Debtors’ rental car operations (the “Leases”);2

2. Pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code, the time period during which the Debtors may assume or reject the Leases is hereby extended through and including the earlier of (a) the effective date of a chapter 11 plan for the Debtors or (b) March 22, 2021 (the “Extension Date”) without prejudice to the right of the Debtors to assume or reject the Leases prior to the Extension Date, or to request additional extensions of time within which to assume or reject the Leases pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code.

2_{Nothing in this stipulation shall be construed as an admission that any particular agreement between} the Lessor and the Lessee is a lease for non-residential real property.

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3. This Stipulation shall be immediately effective and enforceable upon its entry and shall be binding upon (a) the Debtors; (b) any liquidating trustee, plan trustee, plan administrator, distribution agent and/or any other responsible person appointed pursuant to any chapter 11 plan confirmed in these cases; (c) any chapter 11 trustee appointed in these cases; and/or (d) any chapter 7 trustee appointed or elected in these cases.

Dated: December 18, 2020 The Hertz Corporation, as Lessee

By: _______________ WHITE & CASE LLP Ronald K. Gorsich rgorsich@whitecase.com Counsel to the Debtors and Debtors-in-Possession

City of Austin, Texas, as Lessor

By: _______________

KAPLAN KIRSCH & ROCKWELL LLP Steven L. Osit

sosit@kaplankirsch.com

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-3

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Dated: December 18 , 2020

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��...;.S::a::--2----wdITE & CASE LLP Ronald K. Gorsich

rgorsich@whitecase.com

Counsel to the Debtors and Debtors-in-Possession

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-4

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In witness whereof, the Parties have caused this Stipulation to be executed m counterparts, all as of the date hereof.

Dated: December __ , 2020 Lessee

By: _____ _

Ronald K. Gorsich rgorsich@whitecase.com Counsel to the Debtors and Debtors-in-Possession

Lessor

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-5

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Dated: December 18, 2020 _{Lessee ,,,,,t?}

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By:�-S��-WHITE & CASE LLP

Ronald K. Gorsich rgorsich@whitecase.com

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-6

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-7

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-8

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Jeffrey Utterback

Deputy Executive Director 18

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-9

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Debtors.

Chapter 11

STIPULATION EXTENDING THE TIME PERIOD WITHIN WHICH THE DEBTORS MAY ASSUME OR REJECT AN UNEXPIRED LEASE OF

RECITALS

WHEREAS, Miami International Airport (the “Lessor”) and THE HERTZ CORPORATION AND/OR any of its applicable subsidiaries (the “Lessee,”) entered into an agreement

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whereby the Lessor agreed to lease to the Lessee certain non-residential real property located at MIA, to be used in connection with the Debtors’ operations (the “Lease ”);2

WHEREAS, the Lessee has requested, and the Lessor has agreed to grant Lessee, additional time to assume or reject the Lease as permitted under section 365(d)(4)(B)(ii) of the Bankruptcy Code; and

2. Pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code, the time period during which the Debtors may assume or reject the Lease is hereby extended through and including the earlier of (a) the effective date of a chapter 11 plan for the Debtors and (b) March 21, 2021 (the “Extension Date”) without prejudice to the right of the Debtors to assume or reject the Lease prior to the Extension Date, or to request additional extensions of time within which to assume or reject the Lease pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code.

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Dated: December _18_, 2020 Lessee

By: /s/ Ryan C. Zagare____________ Ryan C. Zagare, Esq.

Assistant County Attorney Florida Bar No. 28700 Telephone: (305) 876-7040 Facsimile: (305) 876-7294

Email: rzagare@miami-airport.com rmartin@miami-airport.com

ABIGAIL PRICE-WILLIAMS

MIAMI-DADE COUNTY ATTORNEY P. O. Box 025504

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-10

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Debtors.

Chapter 11

RECITALS

WHEREAS, Port of Portland International Airport (the “Lessor”) and THE HERTZ CORPORATION AND/OR any of its applicable subsidiaries (the “Lessee,”) entered into the (i) Rental

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Car Concession Lease and Operating Agreements, (ii) Facilities Management and Operational Agreement, (iii) Rental Car Limited Service Kiosk Lease, (iv) Facility Lease, (v) Consortium Agreement, (vi) Industry Agreement, (vii) Remote Services Facility Lease, (viii) Permit for Parking, (ix) Permit Pursuant to Ordinances 432-R and 439-R, (x) Underground and Aboveground Storage Tank Agreement for Remote Service Facility and (xi) accompanying Amendments thereto, whereby the Lessor agreed to lease to the Lessee certain non-residential real property located at PDX, to be used in connection with the Debtors’ operations (the “Lease s”);2

WHEREAS, the Lessor, notwithstanding this Agreement, otherwise reserves its rights under the Leases;

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2. Pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code, the time period during which the Debtors may assume or reject the Leases is hereby extended through and including the earlier of (a) the effective date of a chapter 11 plan for the Debtors and (b) March 21, 2021 (the “Extension Date”) without prejudice to the right of the Debtors to assume or reject the Leases prior to the Extension Date, or to request additional extensions of time within which to assume or reject the Leases pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code.

3. This Stipulation shall be immediately effective and enforceable upon its entry and shall be binding upon (a) the Debtors; (b) any liquidating trustee, plan trustee, plan administrator, distribution agent and/or any other responsible person appointed pursuant to any chapter 11 plan confirmed in these cases; (c) any chapter 11 trustee appointed in these cases; and/or (d) any chapter 7 trustee appointed or elected in these cases.

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Dated: December _18_, 2020 Lessee

By: /s/ David Ashton__________ PORT OF PORTLAND

David Ashton

Assistant General Counsel Counsel to Lessor

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-11

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Debtors.

Chapter 11

STIPULATION EXTENDING THE TIME PERIOD WITHIN WHICH THE DEBTORS MAY ASSUME OR REJECT AN UNEXPIRED LEASE OF

RECITALS

WHEREAS, on May 22, 2020 (the “Petition Date”), the Debtors each filed a voluntary petition in this Court for relief under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”). The Debtors’ chapter 11 cases are being jointly administered for procedural purposes only pursuant to an order of this Court [Docket No. 182];

WHEREAS, Port of Seattle (the “Lessor”) and THE HERTZ CORPORATION AND/OR any of its applicable subsidiaries (the “Lessee,”) entered into an agreement whereby the Lessor agreed to

1 _{The last four digits of The Hertz Corporation’s tax identification number are 8568. The} location of the debtors’ service address is 8501 Williams Road, Estero, FL 33928. Due to the large number of debtors in these chapter 11 cases, which are jointly administered for procedural purposes, a complete list of the debtors and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the website of the Debtors’ claims and noticing agent at https://restructuring.primeclerk.com/hertz.

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lease to the Lessee certain non-residential real property located at Seattle-Tacoma International Airport (SEA), to be used in connection with the Debtors’ operations (the “Lease”);2

WHEREAS, the Lessee has requested, and the Lessor has agreed to grant Lessee, additional time to assume or reject the Lease as permitted under section 365(d)(4)(B)(ii) of the Bankruptcy Code; and

2. Pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code, the time period during which the Debtors may assume or reject the Lease is hereby extended through and including the earlier of (a) the effective date of a chapter 11 plan for the Debtors and (b) March 21, 2021 (the “Extension Date”) without prejudice to the right of the Debtors to assume or reject the Lease prior to the Extension Date, or to request additional extensions of time within which to assume or reject the Lease pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code.

2_{Nothing herein shall be construed as an admission by the Debtors that any of their agreements with the Lessor are} in fact non-residential real property leases subject to the section 365(d)(4) assumption/rejection deadline.

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By: _______________ Name: Dawn Hunter Title: Director, Aviation Commercial Management

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AMERICAS 105531464 RLF1 24495206v.1

Exhibit A-12

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In re

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE

Chapter 11

Case No. 20-11218 (MFW)

The Hertz Corporation, et al., 1

(Jointly Administered)

Debtors.

STIPULATION EXTENDING THE TIME PERIOD WITHIN WHICH THE

DEBTORS MAY ASSUME OR REJECT AN UNEXPIRED LEASE OF

The Hertz Corporation and certain of its subsidiaries, debtors and debtors in possession in the

above-captioned chapter 11 cases (together, the "Debtors") hereby stipulate (the "Stipulation")

as follows:

RECITALS

WHEREAS, on May 22, 2020 (the "Petition Date"), the Debtors each filed a voluntary

petition in this Court for relief under chapter 11 of title 11 of the United States Code (the

"Bankruptcy Code"). The Debtors' chapter 11 cases are being jointly administered for

procedural purposes only pursuant to an order of this Court [Docket No. 182];

WHEREAS, the Debtors continue to manage and operate their businesses as debtors in possession pursuant to sections 1107 and 1108 of the Bankruptcy Code;

WHEREAS, City of San Jose-Mineta San Jose International Airport (the "Lessor") and

THE HERTZ CORPORATION AND/OR any of its applicable subsidiaries (the "Lessee,") entered into

The last four digits of The Hertz Corporation's tax identification number are 8568. The location of the debtors' service address is 850 I Williams Road, Estero, FL 33928. Due to the large number of debtors in these chapter 11 cases, which are jointly administered for procedural purposes, a complete list of the debtors and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the

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an agreement whereby the Lessor agreed to lease to the Lessee certain non-residential real property

located at SJC, to be used in connection with the Debtors' operations (the "Lease");2

WHEREAS, on October 8, 2020, the United States Bankruptcy Court for the District of

Delaware (the "Bankruptcy Court") entered that certain Order Extending Time to Assume or

Reject Unexpired Leases of Non-Residential Real Property [D.I. 1458], thereby extending the period within which the Debtors must assume or reject unexpired leases of non-residential real

property to and through December 21, 2020;

WHEREAS, the Lessee has requested, and the Lessor has agreed to grant Lessee,

additional time to assume or reject the Lease as permitted under section 365(d)(4)(B)(ii) of the

Bankruptcy Code; and

WHEREAS, the Parties desire to memorialize their agreement in this Stipulation.

AGREEMENT

1. The foregoing Recitals are true and correct and are incorporated herein by

reference.

2. Pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code, the time period during

which the Debtors may assume or reject the Lease is hereby extended through and including the

earlier of (a) the effective date of a chapter 11 plan for the Debtors and (b) March 21, 2021 (the

"Extension Date") without prejudice to the right of the Debtors to assume or reject the Lease prior

to the Extension Date, or to request additional extensions of time within which to assume or reject

the Lease pursuant to section 365(d)(4)(B)(ii) of the Bankruptcy Code.

3. This Stipulation shall be immediately effective and enforceable upon its entry and

shall be binding upon (a) the Debtors; (b) any liquidating trustee, plan trustee, plan administrator,

2 _Nothing_herein_{shall be construed as an admission by the Debtors that any of}_their_{agreements with}_{the Lessor}_are

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distribution agent and/or any other responsible person appointed pursuant to any chapter 11 plan confirmed in these cases; ( c) any chapter 11 trustee appointed in these cases; and/or ( d) any chapter 7 trustee appointed or elected in these cases.

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L

By:�S2-�ITE&

CASE LLP

Ronald K. Gorsich rgorsich@whitecase.com

Lessor Digitally signed by Judy M.

Ross

'· ) Date: 2020.12.18 13:45:09 By: _______ -oa·oo·

Name: Judy M. Ross Title: Assistant Director