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Case 16-42529 Doc 53 Filed 04/13/16 Entered 04/13/16 12:50:57 Main Document <br />Pg2of31 <br />Fees (as such term is defined below) and (iv) all ESIS Payments (as such term is defined below) <br />(collectively, the "Insurance Obligations"); (c) authorizing them to pay all prepetition Workers' <br />Compensation Liabilities (as such term is defined below); and (d) authorizing all applicable <br />banks and other financial institutions (collectively, the "Banks") to receive, process, honor and <br />pay all related checks and electronic payment requests, whether such checks or electronic <br />payment requests were presented before or after the Petition Date, provided that sufficient funds <br />are available and standing in the Debtors' credit in the applicable accounts to cover such checks <br />and fund transfers, and in support thereof, respectfully represent as follows:2 <br />Jurisdiction and Venue <br />This Court has subject matter jurisdiction to consider this matter pursuant <br />to 28 U.S.C. §§ 157 and 1334 and Rule 81-9.01(B)(1) of the Local Rules of the United States <br />District Court for the Eastern District of Missouri. This is a core proceeding pursuant to <br />28 U.S.C. § 157(b). Venue is proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409. <br />Background <br />2. On April 13, 2016 (the "Petition Date"), the Debtors commenced their <br />reorganization cases by filing voluntary petitions for relief under chapter 11 of the Bankruptcy <br />Code. The Debtors are authorized to continue to operate their businesses and manage their <br />properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy <br />Code. <br />3. Debtor PEC is a Delaware corporation headquartered in St. Louis, <br />Missouri. PEC was incorporated in 1998 and became a public company in 2001. Each of the <br />other Debtors is a wholly-owned direct or indirect subsidiary of PEC. <br />Copies of the proposed orders will be made available on the Debtors' case website at <br />http://www.kccllc.net/peabody. <br />-2- <br />