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Case 16-42529 Doc 28 Filed 04/13/16 Entered 04/13/16 11:32:40 Main Document <br />Pg 25 of 31 <br />are made and authorized to be paid in accordance with this Motion without any duty of further <br />inquiry and without liability for relying on such representations. <br />Requests for Immediate Relief and Waiver of Stay <br />47. Pursuant to Rules 6003(b) and 6004(h) of the Federal Rules of Bankruptcy <br />Procedure (the "Bankruptcy Rules"), the Debtors seek the entry of orders granting the relief <br />requested by this Motion on an interim and final basis and, to the extent it applies, a waiver of <br />any stay of the effectiveness of such orders. <br />48. Bankruptcy Rule 6003(b) provides, in relevant part, that "[e]xcept to the extent <br />that relief is necessary to avoid immediate and irreparable harm, the court shall not, within 21 <br />days after the filing of the petition, issue an order granting ... a motion to use, sell, lease, or <br />otherwise incur an obligation regarding property of the estate including a motion to pay all or <br />part of a claim that arose before the filing of the petition." Fed. R. Bankr. P. 6003(b). In other <br />words, where the failure to grant any such requested relief would result in immediate and <br />irreparable harm to the Debtors' estates, the Court may authorize the relief prior to the twenty <br />second day following the Petition Date. Bankruptcy Rule 6004(h) provides that "[a]n order <br />authorizing the use, sale or lease of property other than cash collateral is stayed until the <br />expiration of 14 days after entry of the order, unless the court orders otherwise." Fed. R. Bankr. <br />P. 6004(h). <br />49. As set forth above, in the First Day Declaration and in the Supporting Declaration, <br />it is vital that court grant the relief requested herein and the Debtors submit that ample cause <br />exists to justify: (a) the immediate entry of an Interim Order granting the interim relief sought <br />herein pursuant to Bankruptcy Rule 6003(b) to the extent it applies; and (b) a waiver of the 14 - <br />day stay imposed by Bankruptcy Rule 6004(h), to the extent that it applies, with respect to the <br />order. <br />-25- <br />