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Case 16-42529 Doc 32 Filed 04/13/16 Entered 04/13/16 11:43:47 Main Document <br />Pg 1 of 21 75922-3 <br />RECEIVED <br />�,Pi� 2 2Q16 UNITED STATES BANKRUPTCY COURT <br />DIV�ING AND SAFETYTERN D TION EASTERN DISTRICT OF <br />MISSOURI <br />MI <br />In re: Case No. 16-42529 <br />CHAPTER 11 <br />Peabody Energy Corporation, et a1., <br />Debtors. <br />(Joint Administration Requested) <br />Hearing Date and Time: <br />TBD <br />Hearing Location: <br />TBD <br />MOTION OF THE DEBTORS AND DEBTORS IN <br />POSSESSION FOR ENTRY OF INTERIM AND FINAL ORDERS <br />(1) AUTHORIZING THE CONTINUATION AND ASSUMPTION OF <br />THE ADM AGREEMENT AND (11) GRANTING RELATED RELIEF <br />Peabody Energy Corporation ("PEC") and certain of its direct and indirect subsidiaries, <br />as debtors and debtors in possession (collectively, the "Debtors"), hereby move this Court, <br />pursuant to sections 105(a), 363, 364 and 365 of title 11 of the United States Code (the <br />"Bankruptcy Code"), for the entry of interim and final orders (a) authorizing the continuation and <br />assumption of the ADM Agreement (as defined below), and (b) granting related relief, and in <br />support thereof, respectfully represent as follows:2 <br />Jurisdiction and Venue <br />1. This Court has subject matter jurisdiction to consider this matter pursuant to <br />28 U.S.C. §§ 157 and 1334 and Rule 81-9.01(B)(1) of the Local Rules of the United States <br />The Debtors and their employer identification numbers are listed on Schedule 1 attached hereto. The <br />addresses for each of the Debtors are set forth in the Debtors' chapter 11 petitions. <br />2 Copies of the proposed orders will be made available on the Debtors' case website at <br />http://www.kccllc.net/peabody. <br />