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Case 16-42529 Doc 23 Filed 04/13/16 Entered 04/13/16 11:20:44 Main Document <br />Pg 17 of 32 <br />immediate and irreparable harm to the estate pending a final hearing." Fed. R. Bankr. P. 4001(c). <br />Bankruptcy Rule 6003(b) provides, in relevant part, that "[e]xcept to the extent that relief is <br />necessary to avoid immediate and irreparable harm, the court shall not, within 21 days after the <br />filing of the petition, issue an order granting ... a motion to use, sell, lease or otherwise incur an <br />obligation regarding property of the estate including a motion to pay all or part of a claim that <br />arose before the filing of the petition." Fed. R. Bankr. P. 6003(b). In other words, where the <br />failure to grant any such requested relief would result in immediate and irreparable harm to the <br />Debtors' estates, the Court may authorize the relief prior to the 22nd day following the Petition <br />Date. Bankruptcy Rule 6004(h) provides that "[a]n order authorizing the use, sale, or lease of <br />property other than cash collateral is stayed until the expiration of 14 days after entry of the order, <br />unless the court orders otherwise." Fed. R. Bankr. P. 6004(h). <br />34. As set forth above and in the First Day Declaration, authorizing the <br />Debtors to continue their Surety Bond Program and granting the other relief requested herein is <br />integral to the Debtors' business operations and necessary to maximize the value of the Debtors' <br />estates, and any failure to do so in the ordinary course of business during the first 21 days of their <br />chapter 11 cases would severely disrupt the Debtors' operations at this critical juncture. <br />Accordingly, the Debtors submit that ample cause exists to justify: (a) the immediate entry of an <br />Interim Order granting the interim relief sought herein pursuant to Bankruptcy Rules 4001(c) and <br />6003(b), to the extent that they apply; and (b) a waiver of the 14 -day stay imposed by <br />Bankruptcy Rule 6004(h), to the extent that it applies, with respect to the order. <br />Reservation of Rights <br />35. Nothing contained herein or in the proposed Interim Order and Final <br />Order is intended or should be construed as: (a) an admission as to the validity or priority of any <br />claim against the Debtors; (b) a waiver of the Debtors' or any party in interest's rights to dispute <br />-17- <br />