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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 20 of 42 <br /> Motion"), in their discretion, to pay and honor certain pre-petition claims for, among other <br /> items, Unpaid Compensation, reimbursable expenses, federal and state withholding taxes and <br /> other amounts withheld (e.g., garnishments, child support, Employees' share of insurance <br /> premiums, taxes and 401(k) contributions), Employees' health benefits, insurance benefits, <br /> flexible spending and/or health savings accounts, workers' compensation benefits, vacation time, <br /> jury duty leave, life insurance, short-term disability coverage and other Employee benefits that <br /> the Debtors have historically provided in the ordinary course of business (collectively, the <br /> "Employee Wages and Benefits"), related expenses and all fees and costs incident to the <br /> foregoing, including amounts to third-party administrators or other administrative service <br /> providers as set forth in the Wages Motion. In addition, the Debtors seek authority to modify, <br /> change and discontinue any of the Employee Wages and Benefits, and to implement new <br /> Employee Wages and Benefits in the ordinary course of business during these chapter 11 cases, <br /> in their discretion, without the need for further Court approval. <br /> 43. Finally, the Debtors request that banks and other financial institutions be <br /> authorized and directed to receive, process, honor and pay all checks presented for payment and <br /> electronic payment requests relating to the foregoing. The Debtors also seek authority to issue <br /> new post-petition checks or fund transfer requests with respect to pre-petition obligations that <br /> may have been dishonored by the banks in respect of the Employees' pre-petition wages, <br /> benefits and deductions, if necessary. <br /> 44. 1 believe that paying pre-petition wages, employee benefits, and similar items will <br /> benefit the Debtors' estates and their creditors by allowing the Debtors' business operations to <br /> continue without interruption. Indeed, I believe that without the relief requested herein, <br /> employees may seek immediate alternative employment opportunities. Such a development <br /> 20 <br />