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Case 16-42529 Doc 53 Filed 04/13116 Entered 04/13/16 12:50:57 Main Document <br />Pg 19 of 31 <br />such as attorneys' fees for certain covered claims; (c) the possible inability to obtain similar types <br />and levels of insurance coverage; and (d) the possible incurrence of higher costs for re- <br />establishing lapsed policies or obtaining new insurance coverage. <br />36. Thus, to the extent the supplementing, amendment, extension, renewal <br />and/or replacement of the Insurance Policies and the Workers' Compensation Insurance Policy <br />are outside the ordinary course of business, the Debtors submit that such actions should <br />nevertheless be approved under section 363(b) of the Bankruptcy Code. <br />Section 363(e) Provides a Basis to Allow the Debtors to Continue Making Payments to the <br />Financiers Under the Financing Agreements <br />37. Section 363(e) of the Bankruptcy Code provides, in relevant part, that "on <br />request of an entity that has an interest in property ... proposed to be used, sold, or leased, by <br />the trustee, the court, with or without a hearing, shall prohibit or condition such use, sale or lease <br />as is necessary to provide adequate protection of such interest." 1 I U.S.C. § 363(e). Under the <br />terms of the Financing Agreements, the Financiers have an interest in, among other things, the <br />financed Insurance Policies related to amounts that may become payable to the Debtors in <br />connection with the financed Insurance Policies, such as unearned premiums or dividends. <br />Where an entity is entitled to adequate protection of its interest, such adequate protection may be <br />provided through "cash payment or periodic cash payments to such entity." 11 U.S.C. § 361(1). <br />Therefore, the Debtors respectfully request the authority to provide the Financiers with adequate <br />protection of their interests by honoring the Debtors' payments and other obligations under the <br />Financing Agreements. <br />The Payment of the Prepetition Insurance Obligations and Workers' Compensation Liabilities <br />Is Appropriate Under Section 105(a) of the Bankruptcy Code and the Doctrine of Necessity <br />38. Here, the Court may authorize payment of the prepetition Insurance <br />Obligations and Workers' Compensation Liabilities pursuant to section 105(a) of the Bankruptcy <br />-19- <br />