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Case 16-42529 Doc 53 Filed 04/13/16 Entered 04/13/16 12:50:57 Main Document <br />Pg 14 of 31 <br />employees to proceed with such claims under the Workers' Compensation Program so that they <br />may be assessed, determined and satisfied, where appropriate, by the Debtors. This requested <br />modification of the automatic stay pertains solely to the assertion of, and proceeding with, the <br />Workers' Compensation Claims. <br />28. The Debtors request that the Court enter an order authorizing them to <br />maintain the Workers' Compensation Program and to continue processing and paying Workers' <br />Compensation Claims in the ordinary course. Because the Debtors are statutorily and/or <br />contractually obligated to maintain the Workers' Compensation Program, their inability to do so <br />may result in adverse legal consequences that disrupt the reorganization process. Thus, pursuant <br />to the Interim Order and Final Order, the Debtors seek authority, but not direction, to: <br />(a) continue the Workers' Compensation Program in the ordinary course of business on a <br />postpetition basis; (b) modify the automatic stay solely to the extent necessary to allow <br />employees to assert and proceed with Workers' Compensation Claims so that such claims may be <br />assessed, determined and satisfied, where appropriate, by the Debtors; and (c) pay, in the <br />ordinary course, all liabilities arising in connection with the Workers' Compensation Program <br />(the "Workers' Compensation Liabilities"), including without limitation, the Workers' <br />Compensation Insurance Premiums, the Workers' Compensation Claims and the Workers' <br />Compensation Administrative Fees, that came due prepetition. <br />29. Although the Debtors do not believe that Court approval is required to <br />maintain their existing Insurance Policies and Workers' Compensation Program following the <br />Petition Date, or to obtain, supplement, amend, extend, renew and/or replace the Insurance <br />Policies and Workers' Compensation Program in the ordinary course of business, this relief is <br />being sought out of an abundance of caution. The Insurance Carriers, Ace (now Chubb), the <br />-14- <br />