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Case 16-42529 Doc 1478 Filed 10/24/16 Entered 10/24/16 20:24:17 Main Document <br />Pg 16 of 99 <br />judgment that the benefits associated with assuming and servicing the Assumed Leases <br />significantly outweigh the costs at this time, and such assumption provides the Debtors' estates <br />with certainty in formulating and implementing a restructuring plan. <br />33. For all of these reasons, the Debtors believe that the assumption of the Assumed <br />Leases is proper under the circumstances and should be approved. Moreover, the Debtors submit <br />that the payment of the Cure Costs will fully satisfy the Debtors' obligations to cure outstanding <br />defaults under the Assumed Leases, pursuant to section 365(b) of the Bankruptcy Code, and <br />should be approved. <br />34. Similarly, the Debtors' proposed rejection of the Rejected Leases is also an <br />appropriate exercise of the Debtors' business judgment, as the Rejected Leases either provide <br />no ongoing benefit to the Debtors' estates or provide benefits that are substantially less than the <br />corresponding costs of continuing to operate under the terms thereof. Rejecting the Rejected <br />Leases will save the Debtors millions of dollars in the aggregate and, for all the reasons set forth <br />herein, is clearly beneficial to the Debtors' estates and creditors. The Debtors have thoroughly <br />considered the available alternatives to rejection of the Rejected Leases and believe that the relief <br />requested herein is most likely to maximize the value of the Debtors' estates. <br />35. In light of the foregoing, the Debtors respectfully request that the Court approve <br />rejection of the Rejected Leases pursuant to section 365(a) of the Bankruptcy Code as a sound <br />exercise of their business judgment. <br />The Debtors Have Satisfied Any Applicable Requirements of Section 365(b) <br />36. Pursuant to section 365(b)(1) of the Bankruptcy Code, if there has been a default <br />in an unexpired lease, a debtor may not assume such lease unless, at the time of assumption of <br />such lease, the debtor (a) cures or provides adequate assurance that it will promptly cure the <br />NAI -1502082594v7 16 <br />