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Case 16-42529 Doc 23 Filed 04/13/16 Entered 04/13/16 11:20:44 Main Document <br />Pg 2 of 32 <br />consequence of these chapter 11 cases with respect to prepetition amounts owed in connection <br />with the Surety Bond Program, and in support thereof, respectfully represent as follows:2 <br />Jurisdiction and Venue <br />1. This Court has subject matter jurisdiction to consider this matter pursuant <br />to 28 U.S.C. §§ 157 and 1334 and Rule 81-9.01(B)(1) of the Local Rules of the United States <br />District Court for the Eastern District of Missouri. This is a core proceeding pursuant to <br />28 U.S.C. § 157(b). Venue is proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409. <br />Background <br />2. On April 13, 2016 (the "Petition Date"), the Debtors commenced their <br />reorganization cases by filing voluntary petitions for relief under chapter 11 of the Bankruptcy <br />Code. The Debtors are authorized to continue to operate their businesses and manage their <br />properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy <br />Code. <br />3. Debtor PEC is a Delaware corporation headquartered in St. Louis, <br />Missouri. PEC was incorporated in 1998 and became a public company in 2001. Each of the <br />other Debtors is a wholly-owned direct or indirect subsidiary of PEC. <br />4. PEC is the world's largest private -sector coal company (by volume), with <br />26 active coal mining operations located in the United States and Australia. The Debtors' <br />domestic mines produce and sell thermal coal, which is primarily purchased by electricity <br />generators. PEC's Australian operations mine both thermal and metallurgical coal, a majority of <br />which is exported to international customers. As of December 31, 2015, Debtor PEC and its <br />subsidiaries' property holdings include 6.3 billion tons of proven and probable coal reserves and <br />2 Copies of the proposed orders will be made available on the Debtors' case website at <br />http://www.kccllc.net/peabody. <br />-2- <br />