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Case 16-42529 Doc 53 Filed 04/13/16 Entered 04/13/16 12:50:57 Main Document <br />Pg 26 of 31 <br />claim against the Debtors; (b) a waiver of the Debtors' or any other party in interest's rights to <br />dispute any claim on any grounds; (c) a promise to pay any claim; (d) an implication or <br />admission that any particular claim is a claim covered by any Insurance Policy; or (e) a request <br />to assume or reject any executory contract or unexpired lease pursuant to section 365 of the <br />Bankruptcy Code. The Debtors expressly reserve the right to contest any claims related to the <br />Insurance Policies under applicable bankruptcy and non -bankruptcy law. <br />Notice <br />50. Notice of this Motion has been given to: (a) Davis Polk & Wardwell LLP <br />and Bryan Cave LLP as counsel to Citibank, N.A. as Administrative Agent for the First Lien <br />Secured Credit Facility and the Debtors' proposed debtor in possession secured credit facility; <br />(b) Brown Rudnick LLP, as counsel to Wilmington Savings Fund Society, FSB as prospective <br />trustee and collateral agent for the Secured Second Lien Notes; (c) Foley & Lardner LLP, as <br />counsel to Wilmington Trust Company as prospective Indenture Trustee for the Unsecured <br />Notes;22 (d) Robinson & Cole LLP, as counsel to U.S. Bank as resigning trustee and collateral <br />agent for the Second Lien Notes, the Unsecured Notes and the Convertible Notes;23 (e) counsel <br />to any ad hoc committees; (f) the Debtors' 50 largest unsecured creditors; (g) Mayer Brown LLP, <br />as counsel to PNC Bank, N.A., as Administrator under the Debtors' prepetition accounts <br />receivable securitization facility; (h) the United Mine Workers of America; (i) the Office of the <br />United States Trustee for the Eastern District of Missouri; 0) the Internal Revenue Service; <br />(k) the Securities and Exchange Commission; (1) the United States Department of the Interior; <br />22 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 />23 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 />-26- <br />