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Case 16-42529 Doc 1478 Filed 10/24/16 Entered 10/24/16 20:24:17 Main Document <br />Pg 20 of 99 <br />affected lessors insofar as their property will be reclaimed and restored by the Debtors to the <br />extent required by applicable law. <br />Request for Waiver of Bankruptcy Rules 6004(h) and 6006(f)(6) <br />42. Bankruptcy Rule 6004(h) provides that "[a]n order authorizing the use, sale, or <br />lease of property other than cash collateral is stayed until the expiration of 14 days after entry of <br />the order, unless the court orders otherwise." Fed. R. Bankr. P. 6004(h). Courts generally <br />authorize the waiver of this provision when the particular circumstances of the case justify the <br />waiver. See, e.g., Yamaha Motor Co., Ltd. v. Perry Hollow Mgmt. Co., Inc. (In re Perry Hollow <br />Mgmt. Co., Inc.), 297 F.3d 34, 41 (1 st Cir. 2002) (holding that the bankruptcy court properly <br />waived the stay imposed under Bankruptcy Rule 6004, because the proposed sale was fair and <br />would preserve the value of the bankruptcy estate). <br />43. As described above, the relief that the Debtors seek in this Motion is necessary for <br />the Debtors to operate their businesses without interruption and to preserve value for their estates. <br />Accordingly, the Debtors respectfully request that the Court waive the 14 -day stay imposed by <br />Bankruptcy Rule 6004(h), as the exigent nature of the relief sought herein justifies immediate <br />relief. <br />44. Similarly, Bankruptcy Rule 6006(f)(6) provides, in relevant part, "[a] motion to <br />reject ... multiple ... unexpired leases that are not between the same parties shall ... be limited to <br />no more than 100 ... unexpired leases." Fed. R. Bankr. P. 6006(f)(6). Courts, however, may <br />waive the requirement of Bankruptcy Rule 6006(f)(6) for cause. See In re Old Carco LLC, <br />406 B.R. 180, 209-10 (Bankr. S.D.N.Y. 2009) (holding, where the debtors sought to reject <br />nearly 800 agreements, that waiving the requirements of Bankruptcy Rule 6006(f)(6) was <br />appropriate; observing that "the 2007 Advisory Committee Note to Rule 6006 states, <br />'[a]n omnibus motion to assume, assign, or reject multiple executory contracts and unexpired <br />NAI -1502082594v7 20 <br />