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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 25 of 42 <br /> 58. Further, if shipping and warehousing charges are not paid, Shippers and <br /> Warehousemen may refuse to perform additional services for the Debtors. In such event, the <br /> Debtors would incur significant additional expenses, such as premium replacement shipping <br /> and warehousing costs, that would likely exceed the amount of unpaid pre-petition shipping <br /> and warehousing charges that the Debtors request the authority to pay hereunder. In many <br /> cases, the Shippers and Warehousemen are irreplaceable and represent the only means to <br /> transport and store the Debtors' Goods. For example, the Debtors' businesses depend critically <br /> on their relationships with several trucking and rail transport companies for which there are no <br /> adequate or available substitutes in the market. The Debtors also rely heavily on operators of <br /> key dock and rail terminals, many of which represent the only practicable method of <br /> transporting the Debtors' Goods to customers in certain markets, particularly overseas. If the <br /> Debtors were unable to promptly locate suitable replacements for these and similar Shippers <br /> and Warehousemen, the Debtors' mining operations would likely be significantly impaired and <br /> could halt altogether. <br /> 59. Because of the commencement of these Chapter I I Cases, certain Shippers and <br /> Warehousemen that hold Goods for delivery to or from the Debtors may refuse to release such <br /> Goods pending receipt of payment for their pre-petition services, which would disrupt the <br /> Debtors' operations. The Debtors believe that a disruption in their sophisticated chain of shipping <br /> and storage arrangements leading from the mines to their customers due to nonpayment of <br /> shipping and warehouse charges could cause substantial delays and great expense to the Debtors' <br /> estates. <br /> B. Service Providers <br /> 25 <br />