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2016-04-25_GENERAL DOCUMENTS - C1982056 (5)
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2016-04-25_GENERAL DOCUMENTS - C1982056 (5)
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Last modified
8/24/2016 6:21:06 PM
Creation date
4/26/2016 9:59:15 AM
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DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
General Documents
Doc Date
4/25/2016
Doc Name
Motion of the Debtors and Debtors in Possession
From
United States Bankruptcy Court
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
MPB
JRS
JLE
Media Type
D
Archive
No
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Case 16-42529 Doc 32 Filed 04/13/16 Entered 04/13/16 11:43:47 Main Document <br />Pg 11 of 21 <br />(Bankr. S.D.N.Y. 1990) (debtor must demonstrate inability to obtain unsecured credit to acquire <br />approval of loan under section 364(c)). In making this showing, the Bankruptcy Code "imposes <br />no duty to seek credit from every possible lender before concluding that such credit is <br />unavailable." In re Snowshoe Co., 789 F.2d at 1088. See also In re Ames Dept. Stores, 115 B.R. <br />at 40 (to obtain relief under section 364(c), "a debtor is not required to seek credit from every <br />possible source"). Courts grant a debtor considerable deference in exercising its sound business <br />judgment to obtain such credit, provided that the agreement is consistent with the provisions of, <br />and policies underlying the Bankruptcy Code. See In re Farmland Indus., Inc., 294 B.R. <br />at 879-81 (court may consider debtor's business judgment, among other things, in determining <br />whether to approve postpetition financing under section 364). <br />23. Inability to provide Credit Support to ADM could cause disruption to the Debtors' <br />operations and expose the Debtors to fluctuations in market prices. Further, with respect to those <br />transactions under the ADM Agreement that are used for hedging purposes, any future posting of <br />collateral will not result in any net loss to the Debtors. ADM will realize on its collateral only if <br />the Debtors owe ADM money. The Debtors will owe money to ADM for hedging transactions, <br />and the collateral that will have been posted will be at risk, only when the prices of the subject of <br />the hedge become favorable to ADM. In these situations, although the Debtors may owe money <br />on account of the transaction, the Debtors' businesses will have benefited from the favorable <br />price movements of the hedge in question. Consequently, the losses, if any, from the transaction <br />that serve as a hedge on operating costs, will likely be offset by gains in the Debtors' operations. <br />Thus, the benefits of the Debtors' hedging strategy at ADM can be realized only by the Debtors <br />continuing their prepetition practices. <br />-11- <br />
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