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Case 16-42529 Doc 53 Piled 04/13/16 Entered 04/13/16 12:50:57 Main Document <br />Pg7of31 <br />insurance premium payment is a fee owed to Lexington Insurance Company ("Lexington") in <br />exchange for Lexington's issuance of property insurance certificates.9 <br />14. The Debtors employ Lockton Companies LLC ("Lockton"); Willis of <br />Tennessee, Inc. (Nashville); Marsh USA Inc., Arthur J. Gallagher & Co. and AON Risk Services <br />Central Inc. (collectively, the "Brokers") as their insurance brokers to assist them with the <br />procurement and negotiation of their Insurance Policies.10 In exchange for the Brokers' services, <br />the Debtors pay them certain fees (collectively, the "Broker Fees"). The Debtors intend to <br />continue utilizing the services provided by the Brokers during these chapter 11 cases and believe <br />the continued use of the Brokers' services is in the best interests of their creditors and estates. <br />The Debtors believe that there are no amounts owed in respect of the Broker Fees as of the <br />Petition Date. <br />15. The Debtors request that the Court enter an order expressly authorizing, <br />but not directing, them to (a) maintain the Insurance Policies and (b) pay all Insurance <br />Obligations (i.e., (i) all premiums owed in connection with the Insurance Policies and any taxes <br />owed in connection therewith, (ii) all Premium Financing Payments, (iii) all Broker Fees and <br />(iv) all ESIS Payments) owed as of the Petition Date. 11 <br />In connection with their obligations to Lexington, the Debtors maintain a letter of credit in the approximate <br />amount of $15 million, issued by U.S. Bank, N.A. ("U.S. Bank") in favor of Lexington. <br />10 The Debtors employ Lockton as their insurance broker to assist them solely with the procurement and <br />negotiation of insurance policies related to their Workers' Compensation Program (as defined below). <br />11 As of the Petition Date, the Debtors do not believe that they owe any Broker Fees, ESIS Payments or <br />premiums in connection with the Insurance Policies. However, the Debtors believe that they may owe <br />certain prepetition de minimis taxes related to premium payments in connection with their prepetition <br />renewal of certain Insurance Policies. For this reason, out of an abundance of caution, the Debtors request <br />the authority to pay all prepetition Insurance Obligations. <br />-7- <br />