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2016-11-02_GENERAL DOCUMENTS - C1992081
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2016-11-02_GENERAL DOCUMENTS - C1992081
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Last modified
11/10/2016 1:13:58 PM
Creation date
11/10/2016 10:32:04 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1992081
IBM Index Class Name
General Documents
Doc Date
11/2/2016
Doc Name
Fifth Omnibus Motion of the Debtors for an Order
From
United States Bankruptcy Court Eastern Disctrict of Missouri Eastern Division
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
DIH
JRS
JHB
Media Type
D
Archive
No
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Case 16-42529 Doc 1478 Filed 10/24/16 Entered 10/24/16 20:24:17 Main Document <br />Pg 15 of 99 <br />(quoting Four B. Corp. v. Food Barn Stores, Inc. (In re Food Barn Stores, Inc.), 107 F.3d 558, <br />567 n.16 (8th Cir. 1997) (alterations in original)). Once a benefit to the estate has been shown, <br />only a finding of "bad faith or gross abuse of ... 'business discretion"' should prevent the debtor <br />from assuming or rejecting the contract. Id. (quoting Lubrizol Enters., Inc. v. Richmond Metal <br />Finishers, Inc., 756 F.2d 1043, 1047 (4th Cir. 1984)). Further, nothing prevents the parties to a <br />contract from agreeing to postpetition modifications to the contract prior to its assumption. <br />See City of Covington v. Covington Landing L.P., 71 F.3d 1221, 1227 (6th Cir. 1995) ("Nothing <br />in the Code suggests that the debtor may not modify its contracts when all parties to the contract <br />consent."). <br />The Debtors Have Determined That Assumption of the Assumed Leases and Rejection of the <br />Rejected Leases Are Appropriate under the Circumstances of This Case <br />32. The Debtors' proposed assumption of the Assumed Leases is an appropriate <br />exercise of the Debtors' business judgment based upon the information available to them. <br />Specifically, for each of the Assumed Leases, the Debtors have assessed the relevant markets and <br />their business operations in light of the current status of their reorganization efforts, recognizing <br />that the coal industry remains in a state of uncertainty. Within these constraints, the Debtors <br />have determined that the Assumed Leases are necessary to their current and future business <br />operations and that the rejection of these Leases would be disruptive and costly. For example, <br />the Debtors have evaluated the significant costs associated with attempting to renegotiate several <br />of the Leases on more favorable terms and believe such renegotiation would be costly, inefficient <br />and uncertain to produce more favorable terms for the Debtors. Furthermore, because several of <br />these Leases relate to properties on which the Debtors already mine and/or process coal, seeking <br />alternative locations would not only pose significant infrastructure investment by the Debtors but <br />also potentially prove less efficient. Accordingly, the Debtors have determined in their business <br />NAI -1502082594v7 15 <br />
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