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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 26 of 42 <br /> 60. The Debtors also seek authority to pay, subject to and in compliance with any DIP <br /> Order, the pre-petition charges of the Service Providers. In order to ensure safe and orderly <br /> working conditions at their mines, the Debtors must repair or replace machine parts and make <br /> on-the-spot repairs to mining machinery on little or no notice. Any disruption in the flow of such <br /> parts or services would immediately affect on-time delivery of coal, which is a key component of <br /> customer satisfaction. Further, any disruption in the flow of parts or services would cause the <br /> Debtors immediate and substantial economic harm and erode their valuable customer base. <br /> 61. Much of the mining equipment in use by the Debtors is highly customized and <br /> industry specific, and the available pool of experienced service providers are therefore limited. <br /> While the Debtors themselves employ on-site mechanics at many of their mines, no mining <br /> company can afford to employ sufficient mechanics to repair and maintain all the specialized <br /> equipment they operate in all possible locations at which service might be required. In many <br /> cases, the Debtors have service agreements (standard in the industry) with third-party <br /> maintenance Service Providers trained and licensed to provide maintenance services at the <br /> Debtors' mining complexes. <br /> 62. The Debtors believe that the Service Providers may be able to assert trade or <br /> mechanics' liens over the Debtors' leaseholds, as well as essential parts, machinery, and other <br /> equipment. In addition, pursuant to section 362(b)(3) of the Bankruptcy Code, the act of <br /> perfecting such liens, to the extent consistent with section 546(b) of the Bankruptcy Code, or to <br /> the extent the act is accomplished within the 30-day period set forth in section 547(e)(2)(A) of <br /> the Bankruptcy Code, is expressly excluded from the automatic stay. Absent payment of the <br /> outstanding pre-petition claims of the Service Providers, the Debtors believe that Service <br /> Providers may refuse or attempt to refuse to provide goods or service for or honor obligations <br /> 26 <br />