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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 28 of 42 <br /> F. DEBTORS' EXPEDITED MOTION FOR ENTRY OF AN ORDER <br /> AUTHORIZING, BUT NOT DIRECTING, THE DEBTORS TO: (A) CONTINUE <br /> INSURANCE COVERAGE ENTERED INTO PRE-PETITION; AND (B) <br /> MAINTAIN POST-PETITION FINANCING OF INSURANCE PREMIUMS <br /> 66. In the ordinary course of their businesses, the Debtors maintain numerous <br /> insurance policies that provide coverage for, among other things, property and equipment <br /> damage, business interruption, commercial general liability, business automobile liability, <br /> pollution liability, umbrella liability, directors' and officers' liability, fiduciary liability, crime, <br /> and personal property (collectively, as described in the relevant motion, the "Insurance <br /> Policies"). <br /> 67. Certain of the Debtors' Insurance Policies require payment of the entire <br /> applicable premium at the inception of the applicable coverage period (the "Financed Policies"). <br /> It is not always in the Debtors' best interests, however, to pay its full insurance premiums up <br /> front. Accordingly, in the ordinary course of business, the Debtors finance the premiums on the <br /> Financed Policies pursuant to premium financing agreement with BankDirect Capital Finance <br /> ("Financing Agreement"). <br /> 68. The Debtors request that the banks and financial institutions on which checks <br /> were drawn, or electronic payment requests were made, in payment of pre-petition obligations <br /> for Insurance Policies be authorized and directed to receive, process, pay, and honor all such <br /> checks and electronic payment requests presented for payment, and all such banks and financial <br /> institutions be authorized to rely on the Debtors' designation of any particular check or electronic <br /> payment request as being approved. <br /> 69. The Insurance Policies, including the Financed Policies, are essential to the <br /> preservation of the value of the Debtors' businesses, properties and assets. In many cases, <br /> insurance coverage such as that provided by the Insurance Policies, including the Financed <br /> 28 <br />