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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 24 of 42 <br /> transport companies, barging companies, freight terminal operators, transloaders, customs <br /> brokers, third-party throughput and ground storage providers, shipping auditing services, <br /> deconsolidators, distributors, logistics management companies, and other third-party service <br /> providers (collectively, the "Shippers") that ship, transport, store, engage in customs business <br /> and otherwise facilitate the movement of the Debtors' coal, goods, operating supplies, parts, <br /> components, materials, equipment or other items (collectively, the "Goods") among the <br /> Debtors' facilities and to their customers, (b) the warehousemen, bailees, storage facilities, <br /> coal blending operators, and other storage providers (collectively, the "Warehousemen") to <br /> whom Goods are delivered through established national and international distribution <br /> networks to store Goods in transit, and (c) contractors, mechanics and other service providers <br /> (collectively, the "Service Providers" and along with the Shippers and Warehousemen, the <br /> "Lien Claimants" and their claims, the "Lien Claims") that repair, maintain, equip, and <br /> otherwise service necessary equipment, and machinery. <br /> A. Shippers and Warehousemen <br /> 57. The Debtors seek authority to pay, subject to and in compliance with any DIP <br /> Order, certain of the pre-petition shipping and warehousing charges with respect to coal and <br /> other Goods in transit. The services provided by the Shippers and Warehousemen are essential to <br /> the Debtors' day-to-day operations in that they are necessary for the Debtors to transport coal (a) <br /> from mines to preparation plants or directly to customers, (b) from preparation plants to dock/rail <br /> terminals or customers, and (c) from these terminals to more distant domestic and international <br /> customers. At any given time, there are numerous shipments en route to and from various <br /> locations across the country and internationally. Therefore, many of the Shippers and <br /> Warehousemen currently possess Goods that are vital to the Debtors' operations. <br /> 24 <br />