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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 27 of 42 <br /> under existing agreements with the Debtors on a go-forward basis. Accordingly, it is critical to <br /> the Debtors' operations that they maintain their relationships with these essential Service <br /> Providers. <br /> 63. The services, labor, materials, and equipment provided by the Lien Claimants <br /> are central to the Debtors' daily operations. The Debtors' businesses are dependent on the <br /> timely delivery of services and equipment to and from the areas in which they operate. Any <br /> disruption to the Debtors' ability to timely procure equipment, repairs, or materials would <br /> significantly impair the Debtors' businesses and compromise the value of the Debtors' estates to <br /> the detriment of all parties in interest. <br /> 64. Absent payment of the outstanding pre-petition Lien Claims, I understand that <br /> Lien Claimants may refuse or attempt to refuse to provide goods or service for or honor <br /> obligations under existing agreements with the Debtors on a go-forward basis. I also understand <br /> that the Lien Claimants may be able to assert trade or mechanics' liens over the Debtors' <br /> leaseholds, as well as essential parts, machinery, and other equipment. As a result, I believe it is <br /> critical to the continuity of the Debtors' operations that they maintain their relationships with <br /> the Lien Claimants. <br /> 65. I believe the relief requested in this motion is in the best interest of the <br /> Debtors' estates, their creditors and all other parties in interest. Accordingly, the Debtors seek <br /> authorization to pay, in their discretion and subject to and in compliance with any DIP Order, the <br /> Lien Claims in the amount of up to $550,000 on an interim basis and an additional amount of up <br /> to $50,000 on a final basis. <br /> 27 <br />