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Case 16-42529 Doc 32 Filed 04/13/16 Entered 04/13/16 11:43:47 Main Document <br />Pg 17 of 21 <br />Wilmington Trust Company as prospective Indenture Trustee for the Unsecured Notes;4 (d) <br />Robinson & Cole LLP, as counsel to U.S. Bank as resigning trustee and collateral agent for the <br />Second Lien Notes, the Unsecured Notes and the Convertible Notes;s (e) counsel to any ad hoc <br />committees; (f) the Debtors' 50 largest unsecured creditors; (g) Mayer Brown LLP, as counsel to <br />PNC Bank, N.A., as Administrator under the Debtors' prepetition accounts receivable <br />securitization facility; (h) the United Mine Workers of America; (i) the Office of the United <br />States Trustee for the Eastern District of Missouri; 0) the Internal Revenue Service; (k) the <br />Securities and Exchange Commission; (1) the United States Department of the Interior; (m) the <br />United States Department of Labor; (n) the United States Attorney's Office for the Eastern <br />District of Missouri; (o) Pension Benefit Guaranty Corporation; and (p) ADM (collectively, the <br />"Notice Parties"). In light of the nature of the relief requested, the Debtors submit that no further <br />notice is necessary. <br />No Prior Request <br />35. No prior request for the relief sought in this Motion has been made to this or any <br />other Court in connection with these chapter 1 I cases. <br />These include the: (i) 6.00% Senior Notes due November 2018; (ii) 6.50% Senior Notes due <br />September 2020; (iii) 6.25% Senior Notes due September 2021; and the (iv) 7.875% Senior Notes due <br />November 2026. <br />These include the: (i) 6.00% Senior Notes due November 2018; (ii) 6.50% Senior Notes due <br />September 2020; (iii) 6.25% Senior Notes due September 2021; (iv) 7.875% Senior Notes due <br />November 2026; and the (v) Convertible Junior Subordinated Debentures due December 2066. <br />-17- <br />