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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
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No
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Case 16-42529 Doc 1478 Filed 10/24/16 Entered 10/24/16 20:24:17 Main Document <br />Pg8of99 <br />substantially contribute to the Debtors' ability to effect a viable plan of reorganization. <br />Furthermore, the Debtors expressly reserve the right to sell and assign each Assumed Lease at a <br />future date, pursuant to sections 363 and 365(f) of the Bankruptcy Code, if such a situation may <br />apse. <br />18. Furthermore, the Debtors expressly reserve the right to assign each Assumed <br />Lease at a future date pursuant to sections 365(f) and 1123(b)(2)8 of the Bankruptcy Code.9 <br />As of the date of the filing this Motion, the Debtors have not yet finalized a plan of <br />reorganization; however, the Debtors contemplate such a plan may streamline the Debtors' <br />operations, in part, by effecting an internal corporate restructuring. In the event an entity that is <br />designated for merger or dissolution is a counterparty to one of the Assumed Leases, the Debtors' <br />plan of reorganization will provide for the assignment of such Assumed Lease to one of the <br />reorganized debtors. <br />19. As the Debtors continue to review and evaluate the Leases and move forward <br />with the chapter 11 plan process, the Debtors may determine, in their business judgment, that the <br />assumption of certain of the Leases currently identified on the Rejected Leases Schedule <br />(as defined below) is appropriate and provides the maximum benefit to the Debtors' estates <br />(any such Lease, an "Additional Assumed Lease"). The Debtors reserve the right to amend the <br />Assumed Leases Schedule to, among other things, add Additional Assumed Leases at any time <br />up to and including November 9, 2016 (the "Lease Schedule Modification Deadline"). If the <br />Section 1123(b)(2) of the Bankruptcy Code provides: "[A] plan may ... subject to section 365 of this title, <br />provide for the ... assignment of any executory contract or unexpired lease of the debtor not previously <br />rejected under such section ...." <br />The Debtors believe that they are entitled to assign any of the Leases to the extent that (a) such leases are <br />validly assumed and (b) the requirements for assignment under section 365 of the Bankruptcy Code are <br />satisfied. <br />NAI -1502082594v7 <br />
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