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Case 16-42529 Doc 1478 Filed 10/24/16 Entered 10/24/16 20:24:17 Main Document <br />Pg 21 of 99 <br />leases must comply with the procedural requirements set forth in subdivision (f) of the rule, <br />unless the court orders otherwise;"' stating further that, because notice of the proposed rejections <br />was otherwise sufficient, "it would not have advanced the process by requiring the Debtors to <br />file eight separate motions requesting the same relief') (alteration in original; emphasis added). <br />45. The Debtors submit that, as in Old Carco, cause exists here to waive the <br />requirement of Bankruptcy Rule 6006(f)(6). The Debtors have complied with the applicable <br />provisions of Bankruptcy Rule 6006(f) in all other respects, 16 and (a) the individualized <br />Assumption Notices and Rejection Notices served on the counterparties to the Leases and <br />(b) the Assumed Leases Schedule and Rejected Leases Schedule, attached hereto, provide <br />sufficient notice to all affected counterparties of the Debtors' intentions with respect to each of <br />the Leases. Moreover, the notice and objection procedures requested herein will ensure that <br />sufficient notice is provided to lessors in the event that the Debtors modify the schedules prior to <br />the Lease Schedule Modification Deadline. Under these circumstances, the Debtors believe that <br />requiring the Debtors to file more than 27 separate motions to assume or reject the Leases may <br />engender — rather than alleviate — confusion, and would burden the Debtors' estates with <br />unnecessary expenses. Accordingly, the Debtors respectfully submit that cause exists to waive <br />the requirement of Bankruptcy Rule 6006(f)(6). <br />Notice <br />46. In accordance with the Case Management Order, notice of this Motion has been <br />given to (a) all parties whose Leases are the subject of this Motion at their most recently known <br />16 As required b the applicable subdivisions of Bankruptcy Rule 6006 <br />q y pp p y (f), this Motion (including the <br />schedules attached hereto): (a) "state[s] in a conspicuous place that parties receiving the omnibus motion <br />should locate their names and their ... leases listed in the motion;" (b) "list[s] parties alphabetically and <br />identif[ies] the corresponding ... lease;" (c) "specif[ies] the terms, including the curing of defaults, for each <br />requested assumption;" and (d) "[is] numbered consecutively with other omnibus motions to assume, assign, <br />or reject executory contracts or unexpired leases." Fed. R. Bankr. P. 6006(f). <br />NAI -1502082594x7 21 <br />