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Case 16-42529 Doc 32 Filed 04/13/16 Entered 04/13/16 11:43:47 Main Document <br />Pg 16 of 21 <br />or lease of property other than cash collateral is stayed until the expiration of 14 days after entry <br />of the order, unless the court orders otherwise." Fed. R. Bankr. P. 6004(h). <br />32. As set forth above and in the Declaration of James A. Tichenor (the "Tichenor <br />Declaration"), it is vital that the Court grant the relief requested herein and the Debtors submit <br />that ample cause exists to justify: (a) the immediate entry of the order granting the relief sought <br />herein pursuant to Bankruptcy Rules 4001(c) and 6003(b) to the extent that they apply; and (b) a <br />waiver of the 14 -day stay imposed by Bankruptcy Rule 6004(h), to the extent that it applies, with <br />respect to the order. <br />Reservation of Rights <br />33. Nothing contained herein or in the proposed order is intended or should be <br />construed as: (a) an admission as to the validity of any claim, security interest or lien against any <br />of the Debtors or non -Debtor affiliates; (b) a waiver of the Debtors' or any other party in <br />interest's rights to dispute any claim, security interest or lien on any grounds; (c) a promise or <br />requirement to pay any claim; or (d) a waiver or limitation of the Debtors' rights under the <br />Bankruptcy Code or any other applicable law. <br />Notice <br />34. 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 />-16- <br />