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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 19 of 42 <br /> C. DEBTORS' MOTION FOR INTERIM AND FINAL ORDERS (1) AUTHORIZING, <br /> BUT NOT DIRECTING, THE DEBTORS TO (A) PAY AND HONOR CERTAIN <br /> PRE-PETITION CLAIMS FOR WAGES, SALARIES, BONUSES AND OTHER <br /> COMPENSATION AND WITHHOLDINGS AND DEDUCTIONS; (B) CONTINUE <br /> EMPLOYEE BENEFIT PROGRAMS IN THE ORDINARY COURSE OF <br /> BUSINESS; AND (C) PAY CERTAIN REIMBURSABLE EXPENSES; (I1) <br /> AUTHORIZING, BUT NOT DIRECTING, THE DEBTORS TO MAKE <br /> DEDUCTIONS FROM EMPLOYEE PAYCHECKS; AND (III) AUTHORIZING <br /> AND DIRECTING BANKS AND OTHER FINANCIAL INSTITUTIONS TO <br /> RECEIVE, PROCESS, HONOR AND PAY ALL CHECKS PRESENTED FOR <br /> PAYMENT AND ELECTRONIC PAYMENT REQUESTS MADE BY THE <br /> DEBTORS RELATING TO THE FOREGOING <br /> 40. The Debtors employ approximately 557 employees (the "Employees"), most of <br /> whom are based in Kentucky, Ohio and West Virginia. The Employees include approximately <br /> 124 salaried Employees and 433 hourly Employees, none of which are subject to a collective <br /> bargaining agreement. <br /> 41. The Employees performed a variety of critical functions, including overseeing <br /> and performing the Debtors' coal mining and processing operations during the pre-petition <br /> period, which added significant value to the Debtors' estates. The Employees' skills, knowledge <br /> and understanding of the Debtors' infrastructure and operations are essential to maintain and <br /> maximize the value of the Debtors' assets and business. The Debtors' payroll runs at multiple <br /> periods, all in arrears, and the Debtors believe that, as of the Petition Date, approximately <br /> $674,189 in accrued wages, salaries, overtime pay, and other compensation (excluding <br /> reimbursable expenses, vacation pay, severance pay, deferred compensation, and incentive bonus <br /> pay) earned prior to the Petition Date (the "Unpaid Compensation") remains unpaid to <br /> Employees. <br /> 42. To minimize the personal hardship that the Employees will suffer if pre-petition <br /> employee-related obligations are not paid when due or as expected and to maintain morale of the <br /> Employees during the chapter 11 cases, the Debtors hereby seek authority (the "Wages <br /> 19 <br />