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Case 16-42529 Doc 53 Filed 04/13/16 Entered 04/13/16 12:50:57 Main Document <br />Pg4of31 <br />found in the Declaration of Amy Schwetz, Executive Vice President and Chief Financial Officer <br />of Debtor PEC, in Support of First Day Motions of Debtors and Debtors in Possession (the "First <br />Day Declaration"), which was filed contemporaneously herewith and is incorporated herein by <br />reference. <br />Facts Relevant to This Motion <br />The Debtors' General Insurance Policies <br />7. In the ordinary course of their businesses, the Debtors maintain numerous <br />insurance policies that provide coverage for, among other things, general commercial liability, <br />property damage, environmental liability, automobile damage and liability, aviation liability, <br />marine liability, directors and officers liability, transit damage, crime and fiduciary liability and <br />various other property -related and general liability (collectively, as such policies may be <br />supplemented, amended, extended, renewed and/or replaced, the "Insurance policies ',).3 <br />The Insurance Policies are essential to preserve the Debtors' businesses and are, in some cases, <br />required by various laws, regulations and contracts that govern the Debtors' businesses. <br />8. The Debtors maintain the Insurance Policies through multiple insurance <br />carriers (collectively, the "Insurance Carriers"). The names of the Insurance Policies, the <br />Insurance Carriers, the lines of coverage and the coverage periods are set forth on Exhibit A, <br />attached hereto.4 <br />9. The Debtors pay approximately $16.7 million in aggregate annual <br />premiums for the Insurance Policies. Most of the Debtors' insurance premiums are determined <br />The Debtors also have insurance coverage with respect to their Workers' Compensation Program and <br />related obligations, which is more fully described below. <br />The Insurance Policies summarized on Exhibit A are representative only and are not intended to restrict <br />the Debtors from changing carriers or programs or adding different types of insurance in the reasonable <br />exercise of the Debtors' business judgment in the ordinary course of business. <br />In <br />