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Case 16-42529 Doc 53 Filed 04/13/16 Entered 04/13/16 12:50:57 Main Document <br />Pg 25 of 31 <br />47. 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. 4001(c). <br />Bankruptcy Rule 6003(b) provides, in relevant part, that "[e]xcept to the extent that relief is <br />necessary to avoid immediate and irreparable harm, the court shall not, within 21 days after the <br />filing of the petition, issue an order granting ... a motion to use, sell, lease or otherwise incur an <br />obligation regarding property of the estate including a motion to pay all or part of a claim that <br />arose before the filing of the petition." Fed. R. Bankr. P. 6003(b). In other words, where the <br />failure to grant any such requested relief would result in immediate and irreparable harm to the <br />Debtors' estates, the Court may authorize the relief prior to the 22nd day following the Petition <br />Date. Bankruptcy Rule 6004(h) provides that "[a]n order authorizing the use, sale, or lease of <br />property other than cash collateral is stayed until the expiration of 14 days after entry of the order, <br />unless the court orders otherwise." Fed. R. Bankr. P. 6004(h). <br />48. As set forth above and in the First Day Declaration, it is vital that the <br />Court immediately grant the relief requested herein as the failure to do so would severely disrupt <br />the Debtors' operations at this critical juncture. Accordingly, the Debtors submit that ample <br />cause exists to justify: (a) the immediate entry of an Interim Order granting the interim relief <br />sought herein pursuant to Bankruptcy Rules 4001(c) and 6003(b), to the extent that they apply; <br />and (b) a waiver of the 14 -day stay imposed by Bankruptcy Rule 6004(h), to the extent that it <br />applies, with respect to the order. <br />Reservation of Rights <br />49. Nothing contained herein or in the proposed Interim Order and Final <br />Order is intended or should be construed as: (a) an admission as to the validity or priority of any <br />-25- <br />