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Case 16-42529 Doc 23 Filed 04/13/16 Entered 04/13/16 11:20:44 Main Document <br />Pg 18 of 32 <br />any claim on any grounds; (c) a promise to pay any claim; (d) an implication or admission that <br />any particular claim against the Debtors is a claim arising under the Surety Bond Program; or <br />(e) a request to assume or reject any executory contract or unexpired lease pursuant to section <br />365 of the Bankruptcy Code. The Debtors expressly reserve the right to contest any claims <br />related to the Surety Bond Program under applicable bankruptcy and non -bankruptcy law. <br />Notice <br />36. Notice of this Motion has been given to: (a) Davis Polk & Wardwell LLP and <br />Bryan Cave LLP as counsel to Citibank, N.A. as Administrative Agent for the First Lien Secured <br />Credit Facility and the Debtors' proposed debtor in possession secured credit facility; (b) Brown <br />Rudnick LLP, as counsel to Wilmington Savings Fund Society, FSB as prospective trustee and <br />collateral agent for the Secured Second Lien Notes; (c) Foley & Lardner LLP, as counsel to <br />Wilmington Trust Company as prospective Indenture Trustee for the Unsecured Notes;' (d) <br />Robinson & Cole LLP, as counsel to U.S. Bank as resigning trustee and collateral agent for the <br />Second Lien Notes, the Unsecured Notes and the Convertible Notes;8 (e) counsel to any ad hoc <br />committees; (f) the Debtors' 50 largest unsecured creditors; (g) Mayer Brown LLP, as counsel to <br />PNC Bank, N.A., as Administrator under the Debtors' prepetition accounts receivable <br />securitization facility; (h) the United Mine Workers of America; (i) the Office of the United <br />States Trustee for the Eastern District of Missouri; 0) the Internal Revenue Service; (k) the <br />Securities and Exchange Commission; (1) the United States Department of the Interior; (m) the <br />United States Department of Labor; (n) the United States Attorney's Office for the Eastern <br />These include the: (i) 6.00% Senior Notes due November 2018; (ii) 6.50% Senior Notes due <br />September 2020; (iii) 6.25% Senior Notes due September 2021; and the (iv) 7.875% Senior Notes due <br />November 2026. <br />These include the: (i) 6.00% Senior Notes due November 2018; (ii) 6.50% Senior Notes due <br />September 2020; (iii) 6.25% Senior Notes due September 2021; (iv) 7.875% Senior Notes due <br />November 2026; and the (v) Convertible Junior Subordinated Debentures due December 2066. <br />-18- <br />