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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 30 of 42 <br /> inevitably harm the Debtors and their estates as well as seriously jeopardize the Chapter 11 <br /> Cases. It is, therefore, critical that utility services continue uninterrupted. <br /> 72. I understand that, pursuant to section 366(c)(2) of the Bankruptcy Code, a utility <br /> provider may alter, refuse, or discontinue a chapter I I debtor's utility service if the utility does <br /> not receive from the debtor or the trustee adequate "assurance of payment" within 30 days of the <br /> commencement of the debtor's chapter 1 I case. To comply with the requirements of section 366 <br /> of the Bankruptcy Code, the Debtors seek an order of this Court authorizing them to deposit <br /> $100,000 into a segregated account at PNC Bank (the"Adequate Assurance Deposit"), which <br /> amount represents the Debtors' calculation of the cost of two weeks' worth of utility service, <br /> based on recent historical averages provided that such Utility Providers are not currently paid in <br /> advance for its services and/or do not already hold a deposit equal to or greater than the <br /> Adequate Assurance Deposit (which existing deposit shall be deemed to be the Adequate <br /> Assurance Deposit). <br /> H. MOTION OF THE DEBTORS FOR ENTRY OF INTERIM AND FINAL <br /> ORDERS AUTHORIZING DEBTORS TO CONTINUE AND RENEW THEIR <br /> SURETY BOND PROGRAMS <br /> 73. The Debtors, in the ordinary course of their business and on a regular basis, are <br /> required to provide surety bonds (collectively, the "Surety Bonds") to various third parties to <br /> secure the Debtors' payment or performance of certain obligations (the "Surety Bond <br /> Program"). In particular, the Debtors commonly (although not exclusively) provide Surety <br /> Bonds to governmental units or other public agencies pursuant to statutory requirements. Debtors <br /> provide Surety Bonds to secure obligations to various entities, including municipalities, state and <br /> federal regulatory agencies, customers, and suppliers. As of the Petition Date, the Debtors had <br /> approximately $41,300,000.00 in outstanding Surety Bonds. <br /> 30 <br />