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Case 16-42529 Doc 108 Filed 04/14/16 Entered 04/14/16 17:28:56 Main Document <br />Pg 14 of 70 <br />now have or may have, or that their successors or assigns hereafter can or may have against any <br />of the Released Parties for or by reason of any act, omission, matter, cause or thing whatsoever <br />arising at any time on or prior to the date of this Interim Order, whether such Released Claims <br />are matured or unmatured or known or unknown or contingent, liquidated or unliquidated; <br />(1) Notwithstanding anything to the contrary herein except and subject to (i) <br />paragraph 13(i) of this Interim Order and (ii) paragraph 19 of this Interim Order with respect to <br />whether any cash as of the Petition Date constitutes cash collateral (as that term is defined in <br />section 363(a) of the Bankruptcy Code), nothing in this Interim Order prejudices the rights, <br />claims or defenses of any party in interest (including the Specified Lenders') with respect to the <br />CNTA Dispute (as defined in the DIP Credit Agreement) or whether any cash as of the Petition <br />Date constitutes cash collateral (as that term is defined in section 363(a) of the Bankruptcy <br />Code). The Pre -Petition Secured Parties, the Debtors and all other parties in interest (including <br />the Specified Lenders) reserve all rights, claims and defenses with respect to the CNTA Dispute <br />and whether any cash as of the Petition Date constitutes cash collateral (as that term is defined in <br />section 363(a) of the Bankruptcy Code). <br />5. Findings Regarding the DIP Financing. <br />(a) Good cause has been shown for the entry of this Interim Order. <br />(b) The Debtor Loan Parties have an immediate need to obtain the DIP <br />Financing, and the Debtors have an immediate need to continue to use Cash Collateral to permit, <br />among other things, the orderly continuation of the operation of their businesses; to maintain <br />business relationships with vendors, suppliers and customers; to make payroll; to make capital <br />expenditures; to fulfill other bonding and regulatory requirements; to pay the Adequate <br />Protection Obligations; and to satisfy other working capital and operational needs. The access of <br />14 <br />