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Case 16-42529 Doc 28 Filed 04/13/16 Entered 04/13/16 11:32:40 Main Document <br />Pg2of31 <br />goods received by the Debtors within 20 days of the Petition Date without limit on the maximum <br />aggregate amount, as these claims if allowed would be entitled to administrative priority <br />pursuant to section 503(b)(9) of the Bankruptcy Code; (b) approving a procedure to address <br />those vendors who repudiate or otherwise refuse to honor their contractual obligations to the <br />Debtors; and (c) granting certain related relief, and in support thereof, respectfully represent as <br />follows:2 <br />Jurisdiction and Venue <br />This Court has subject matter jurisdiction to consider this matter pursuant to <br />28 U.S.C. §§ 157 and 1334 and Rule 81-9.01(B)(1) of the Local Rules of the United States <br />District Court for the Eastern District of Missouri. This is a core proceeding pursuant to <br />28 U.S.C. § 157(b). Venue is proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409. <br />Background <br />2. On April 13, 2016 (the "Petition Date"), the Debtors commenced their <br />reorganization cases by filing voluntary petitions for relief under chapter I 1 the Bankruptcy <br />Code. The Debtors are authorized to continue to operate their businesses and manage their <br />properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy <br />Code. <br />3. Debtor PEC is a Delaware corporation headquartered in St. Louis, Missouri. PEC <br />was incorporated in 1998 and became a public company in 2001. Each of the other Debtors is a <br />wholly-owned direct or indirect subsidiary of PEC. <br />4. PEC is the world's largest private -sector coal company (by volume), with 26 <br />active coal mining operations located in the United States and Australia. The Debtors' domestic <br />2 Copies of the proposed orders will be made available on the Debtors' case website at <br />http://www.kccllc.net/peabody. <br />-2- <br />