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Case 1:20-bk-12043 Doc 3 Filed 07/22/20 Entered 07/22/20 17:38:25 Desc Main <br /> Document Page 18 of 42 <br /> relief sought in each of the First Day Motions and Applications is tailored to meet the goals <br /> described above and, ultimately, will be critical to the Debtors' ability to reorganize successfully. <br /> A. MOTION FOR ENTRY OF AN ORDER PURSUANT TO RULE 1015(B) OF THE <br /> FEDERAL RULES OF BANKRUPTCY PROCEDURE DIRECTING JOINT <br /> ADMINISTRATION OF THE DEBTORS' CHAPTER 11 CASES <br /> 37. The Debtors will present a motion requesting the entry of an order providing for <br /> the joint administration, but not the substantive consolidation, of the chapter 11 cases. I believe <br /> that the joint administration of the Debtors' respective estates is warranted and will promote <br /> efficiency. <br /> 38. Given the integrated nature of the Debtors' operation, specifically, the fact that <br /> the Debtors share common ownership, share resources and management systems, and the <br /> Debtors will be borrowers and/or guarantors under the Debtors' anticipated post-petition <br /> financing facility, joint administration of the motions, hearings, and orders in the chapter 11 <br /> cases will affect each and every Debtor entity. Accordingly, I submit that the joint <br /> administration of these chapter 11 cases is in the best interests of their creditors and all other <br /> parties in interest. <br /> B. MOTION FOR EXTENSION OF TIME FOR THE FILING OF SCHEDULES <br /> AND STATEMENTS OF FINANCIAL AFFAIRS <br /> 39. Because of the size and complexity of the Debtors' businesses and financial <br /> affairs, the Debtors will move for entry of an order granting them an extension of time until 30 <br /> days following the Petition Date to gather information necessary to complete and file the <br /> required: (a) schedules of assets and liabilities; (b) schedules of executory contracts and <br /> unexpired leases; and (c) statements of financial affairs. I believe this will assist in the general <br /> administrative efficiency of these chapter 11 cases and allow the Debtors to immediately begin <br /> maximizing value for the Debtors' creditors. <br /> 18 <br />