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2016-04-25_GENERAL DOCUMENTS - C1992081 (3)
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2016-04-25_GENERAL DOCUMENTS - C1992081 (3)
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Last modified
8/24/2016 6:21:07 PM
Creation date
4/26/2016 9:59:20 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1992081
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
DRNS
Permit Index Doc Type
General Correspondence
Email Name
MPB
JRS
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 15 of 21 <br />29. As discussed above, the Debtors' decision to continue the ADM Agreement and <br />enter into transactions thereunder is a sound exercise of the Debtors' business judgment. As part <br />of the assumption, the Debtors will continue to perform under the ADM Agreement, including <br />providing Credit Support as required. As with the Debtors' other business decisions related to <br />continuation of the ADM Agreement, the Debtors' decision to assume the ADM Agreement <br />satisfies the business judgment test. Thus, this Court should authorize the Debtors to assume the <br />ADM Agreement under section 365 of the Bankruptcy Code. <br />Requests for Immediate Relief and Waiver of Stay <br />30. Pursuant to Rules 4001(c), 6003(b) and 6004(h) of the Federal Rules of <br />Bankruptcy Procedure (the "Bankruptcy Rules"), the Debtors seek the entry of orders granting <br />the relief requested by this Motion on an interim and final basis and, to the extent it applies, a <br />waiver of any stay of the effectiveness of such order. <br />31. Bankruptcy Rule 4001(c) provides that, when presented with a motion for <br />authority to obtain credit, the "court may conduct a hearing before [ 14 days after service of the <br />motion], but the court may authorize the obtaining of credit only to the extent necessary to avoid <br />immediate and irreparable harm to the estate pending a final hearing." Fed. R. Bankr. P. <br />4001(c). Bankruptcy Rule 6003(b) provides, in relevant part, that "[e]xcept to the extent that <br />relief is necessary to avoid immediate and irreparable harm, the court shall not, within 21 days <br />after the filing of the petition, issue an order granting ... a motion to use, sell, lease or otherwise <br />incur an obligation regarding property of the estate including a motion to pay all or part of a <br />claim that arose before the filing of the petition." Fed. R. Bankr. P. 6003(b). In other words, <br />where the failure to grant any such requested relief would result in immediate and irreparable <br />harm to the Debtors' estates, the Court may authorize the relief prior to the 22nd day following <br />the Petition Date. Bankruptcy Rule 6004(h) provides that "[a]n order authorizing the use, sale, <br />-15- <br />
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