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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF INDIANA

INDIANAPOLIS DIVISION

In re:

USA GYMNASTICS,

¹

Debtor.

Chapter 11 Case No. 18-09108-RLM-11

THIRD JOINT MOTION TO CONTINUE DEADLINE TO SUBMIT PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON STAY CROSS-MOTIONS

USA Gymnastics, as debtor and debtor in possession in the above-captioned chapter 11 case (the “Debtor”) and Tasha Schwikert-Warren, Jordan Cobbs, Jane ED Doe, and Kennedy Baker (the “Plaintiffs”) jointly move to continue the deadline to submit proposed findings of fact and conclusions of law on the Debtor’s Motion To Enforce The Automatic Stay [Dkt. 1459] and the Certain Survivors’ Motion For (I) Determination Of Scope Of Automatic Stay, (II) Stay Relief, Or (III) Injunction Against Debtor’s Interference With Plaintiffs’ Legitimate Discovery [Dkt. 1460] (together, the “Stay Motions”), and state as follows:

1. The Court held a hearing on the Stay Motions on April 28, 2021. At the conclusion of the hearing, the Court took the Stay Motions under submission and directed the Debtor and the Plaintiffs (the “Parties”) to separately submit draft orders with proposed findings of fact and conclusions of law (the “Proposed Orders”). The Court set May 12, 2021 as the deadline for the submission of the Proposed Orders, which the Court subsequently extended through and including September 20, 2021. (Dkt. 1540.)

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The last four digits of the Debtor’s federal tax identification number are 7871. The location of the Debtor’s principal office is 1099 N. Meridian St., Suite 800, Indianapolis, Indiana 46204.

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2. The Parties have agreed it would be productive to hold the Stay Motions in abeyance while the Debtor seeks confirmation of its proposed plan of reorganization (Dkt. 1551) (the “Proposed Chapter 11 Plan”), subject to extensions mutually agreed to by the Parties and accepted by the Court. In light of this agreement, the Parties jointly request that the Court continue the deadline to submit Proposed Orders on the Stay Motions until at least December 31, 2021, subject to further extensions mutually agreed upon by the parties and accepted by the Court.

3. Plaintiffs reserve all rights to file and make objections to the Proposed Chapter 11 Plan or Debtor’s Disclosure Statement, and nothing in this Joint Motion shall be construed in any way as a waiver of such objections or acquiescence or agreement to the Proposed Chapter 11 Plan or Debtor’s Disclosure Statement.

WHEREFORE, the Debtor and the Plaintiffs respectfully request that the Court enter the proposed order attached hereto as Exhibit A and continue the deadline to submit Proposed Orders on the Stay Motions through and including December 31, 2021, subject to further extensions mutually agreed upon by the parties and accepted by the Court, and grant all other just and proper relief.

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Dated: September 15, 2021 Jointly submitted,

JENNER & BLOCK LLP By: /s/ Catherine Steege

Catherine L. Steege (admitted pro hac vice) Dean N. Panos (admitted pro hac vice) Melissa M. Root (#24230-49)

Adam T. Swingle (admitted pro hac vice) 353 N. Clark Street

Chicago, Illinois 60654 Tel: (312) 923-2952 Fax: (312) 840-7352 [email protected] [email protected] [email protected] [email protected] Counsel for the Debtor

PANISH, SHEA & BOYLE, LLP By: /s/ Jesse M. Creed Kevin Boyle

Jesse M. Creed (admitted pro hac vice) 11111 Santa Monica Blvd., Suite 700 Los Angeles, CA 90025

Tel: (310) 477-1700 [email protected] Counsel for Plaintiffs

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EXHIBIT A

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF INDIANA

INDIANAPOLIS DIVISION

In re:

USA GYMNASTICS,

¹

Debtor.

Chapter 11 Case No. 18-9108-RLM-11

ORDER GRANTING THIRD JOINT MOTION TO CONTINUE DEADLINE TO SUBMIT PROPOSED FINDINGS OF FACT AND

CONCLUSIONS OF LAW ON STAY CROSS-MOTIONS

This matter came before the Court on the Third Joint Motion To Continue Deadline To Submit Proposed Findings Of Fact And Conclusions Of Law On Stay Cross-Motions (the

“Motion”) filed by USA Gymnastics (the “Debtor”) and Tasha Schwikert-Warren, Jordan Cobbs, Jane ED Doe, and Kennedy Baker (the “Plaintiffs”) for an order continuing the deadline set by the Court’s Order Granting Second Joint Motion To Continue Deadline To Submit Proposed

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The last four digits of the Debtor’s federal tax identification number are 7871. The location of the Debtor’s principal office is 1099 N. Meridian St., Suite 800, Indianapolis, Indiana 46204.

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Findings Of Fact And Conclusions Of Law On Stay Cross-Motions [Dkt. 1540] for the Debtor and Plaintiffs to submit proposed findings of fact and conclusions of law with respect to the Debtor’s Motion To Enforce The Automatic Stay [Dkt. 1459] and the Certain Survivors’ Motion For (I) Determination Of Scope Of Automatic Stay, (II) Stay Relief, Or (III) Injunction Against Debtor’s Interference With Plaintiffs’ Legitimate Discovery [Dkt. 1460] (together, the “Stay Motions”), through and including at least December 31, 2021; and the Court hereby determines the Motion should be GRANTED.

IT IS HEREBY ORDERED:

1. The Motion is GRANTED.

2. The deadline for the Debtor and the Plaintiffs to submit proposed findings of fact and conclusions of law on the Stay Motions is extended through and including December 31, 2021, subject to further extensions mutually agreed upon by the parties and accepted by this Court.

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