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Case 16-42529 Doc 28 Filed 04/13/16 Entered 04/13/16 11:32:40 Main Document <br />Pg4of31 <br />(the "First Day Declaration"). In further support of this Motion and certain other requests for <br />first day relief, the Debtors have filed the Declaration of Paul M. Wagner in Support of Certain <br />Request for First Day Relief Related to Suppliers (the "Supporting Declaration"). Both the First <br />Day Declaration and the Supporting Affidavit were filed contemporaneously herewith and are <br />incorporated herein by reference. <br />The Essential Supplier Claims and 20 -Day Administrative Claims <br />Overview of the Need for Relief <br />7. The Debtors are highly mindful of their fiduciary obligations to seek to preserve <br />and maximize the value of their estates. Consequently, the Debtors' managers have made <br />maintaining relationships with their customers one of the Debtors' primary goals as they <br />transition into chapter 11. Providing seamless delivery of its coal to those customers is key to <br />meeting this goal. The Debtors' ability to continually deliver coal, in turn, depends on certain <br />vendors providing, without interruption, goods and services to the Debtors. <br />The Debtors' business of mining and processing coal cannot function without the <br />specially -designed equipment, parts and supplies provided by these not -readily replaceable <br />suppliers. Many of these suppliers are critical to multiple of the Debtors' mining operations. <br />The Debtors also rely on the daily provision of certain industry -specific services, without which <br />the Debtors would likely have to idle operations. Further, to continue coal mining and <br />production, the Debtors must receive regular shipments of specialized coal processing chemicals <br />and minerals to their mines and processing facilities. Even if alternative suppliers chemicals and <br />minerals could be located (which is uncertain), the Debtors likely would incur significant <br />additional costs and delays if forced to suddenly change vendors. In addition, the Debtors' <br />operations could not continue to function, and would not be able to meet critical safety and <br />-4- <br />