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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 29 of 42 <br /> Policies, is required by the diverse regulations, laws and contracts that govern the Debtors' <br /> commercial activities. Accordingly,the Debtors seek authority to make monthly payments in the <br /> approximate amount of$214,352 for the financing of the premiums under the Financed Policies, <br /> subject to and in compliance with any DIP Order <br /> G. MOTION FOR ENTRY OF INTERIM AND FINAL ORDERS (I) APPROVING <br /> THE DEBTORS' PROPOSED ADEQUATE ASSURANCE OF PAYMENT FOR <br /> FUTURE UTILITY SERVICES, (II) PROHIBITING UTILITY COMPANIES <br /> FROM ALTERING, REFUSING, OR DISCONTINUING SERVICES, (III) <br /> APPROVING THE DEBTORS' PROPOSED PROCEDURES FOR RESOLVING <br /> ADEQUATE ASSURANCE REQUESTS, AND (IV) GRANTING RELATED <br /> RELIEF <br /> 70. In operation of their facilities, the Debtors incur utility expenses for, among other <br /> things, water, electricity, internet, and telephone services in the ordinary course of business. <br /> These utility services are provided by approximately forty-three (43) providers (collectively, the <br /> "Utility Providers"). Based on a historical average over the last twelve months, the Debtors <br /> calculate their average monthly costs for Utility Services to be approximately $534,000 per <br /> month. Based on the foregoing, the Debtors estimate that their cost for Utility Services during <br /> the next 30 days (not including any deposits to be paid or any unpaid pre-petition amount that <br /> has already been invoiced) will be approximately $534,000. <br /> 71. Uninterrupted utility services are essential to the Debtors' ongoing business <br /> operations and, therefore, to the success of their chapter 11 efforts. Should the Utility Providers <br /> refuse or discontinue service to the Debtors' facility, even for a brief period, the Debtors' <br /> business operations would be severely disrupted. Simply put, without utility service, the <br /> Debtors' operations will shut down. Continuity of services is particularly critical in this case <br /> because the Debtors have a substantial coal mining and processing operation that relies on <br /> various utilities for continued operation. Failure to maintain continuous operations will <br /> 29 <br />