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Case 16-42529 Doc 53 Filed 04/13/16 Entered 04/13/16 12:50:57 Main Document <br />Pg 18 of 31 <br />compensation statutes may result in suspension of operations); 820 ILL. COMP. STAT. ANN. <br />305/4(d) (failure to maintain workers' compensation insurance may result in suspension of <br />business operations); IND. CODE ANN. § 22-3-4-13(d) (employer who violates Indiana's workers' <br />compensation statutes may be subject to criminal sanctions); N.M. STAT. ANN. § 52-1-62 (failure <br />to file proof of insurance relating to workers' compensation may result in suspension of <br />operations); WYO. STAT. ANN. § 27-14-203(f) (business may be enjoined from continuing <br />operations if business fails to make workers' compensation payments). Further, section <br />1112(b)(4)(C) of the Bankruptcy Code provides that "failure to maintain appropriate insurance <br />that poses a risk to the estate or to the public" is "cause" for mandatory conversion or dismissal <br />of a chapter 11 case. See 11 U.S.C. § 1112(b)(4)(C). Moreover, the Chapter 11 Guidelines (the <br />"Guidelines") of the Office of the United States Trustee for Region 13 (the "United States <br />Trustee") require the Debtors to maintain insurance throughout these chapter 11 cases, make <br />insurance premium payments when due and provide proof of insurance to the United States <br />Trustee. See Guidelines §§ I.I, II. Finally, as directed by Rule 2015-3(B) of the Local Rules of <br />the Bankruptcy Court for the Eastern District of Missouri, debtors in chapter 11 cases must <br />maintain appropriate insurance coverage customarily carried "for the debtor's industry." <br />See Local R. Bankr. P. 2015-3(B). <br />35. Even where coverage is not expressly required by law, the Debtors are <br />nevertheless compelled by sound business practice to maintain essential insurance coverage. <br />Any interruption in such coverage would expose the Debtors to a variety of risks, including: <br />(a) the possible incurrence of direct liability for the payment of claims that otherwise would have <br />been covered by the Insurance Policies or the Workers' Compensation Insurance Policy; (b) the <br />possible incurrence of material costs and other losses that otherwise would have been reimbursed, <br />