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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 32 of 42 <br /> the Debtors could default on various obligations, which could severely disrupt the Debtors' <br /> operations and impair the Debtors' prospects for a successful reorganization to the detriment of <br /> all parties in interest. Moreover, the inability to secure a Surety Bond may require the Debtors to <br /> purchase insurance coverage at greater expense to the Debtors' estates. <br /> 79. Furthermore, the Debtors may need additional bonding capacity not currently <br /> provided under the Surety Bond Program to provide financial assurances to third parties that are <br /> required for the Debtors to continue business operations during the Chapter 11 Cases. The <br /> inability to secure a surety bond may require the Debtors to purchase insurance coverage at <br /> greater expense to the Debtors' estates. Accordingly, to operate their businesses, the Debtors <br /> seek authority to maintain their Surety Bond Program, including by renewing or replacing, as <br /> necessary, existing Surety Bonds and maintaining collateral arrangements similar to those <br /> currently in place, in each case subject to and in compliance with any DIP Order. <br /> I. MOTION OF DEBTORS FOR ENTRY OF AN INTERIM AND FINAL ORDERS: <br /> (I) AUTHORIZING POST-PETITION SECURED FINANCING PURSUANT TO <br /> SECTIONS 105, 361, 362, 364(c)(1), 364(c)(2), 364(c)(3), 364(d)(1), 364(e) AND <br /> 503(b) OF THE BANKRUPTCY CODE; (II) AUTHORIZING THE DEBTORS <br /> TO USE CASH COLLATERAL PURSUANT TO SECTION 363 OF THE <br /> BANKRUPTCY CODE; (III) PROVIDING ADEQUATE PROTECTION TO <br /> THE PRE-PETITION SECURED PARTIES PURSUANT TO SECTIONS 361, <br /> 362, AND 363 OF THE BANKRUPTCY CODE; (IV) MODIFYING THE <br /> AUTOMATIC STAY PURSUANT TO SECTION 362(d) OF THE <br /> BANKRUPTCY CODE; (V) SCHEDULING A FINAL HEARING; AND (VI) <br /> PROVIDING RELATED RELIEF <br /> 70. There are a number of creditors who assert an interest in the Debtors' cash <br /> collateral (the "Cash Collateral Creditors"), including the Prepetition Lenders. The Debtors <br /> have an immediate need to use cash collateral to pay actual, necessary, ordinary course operating <br /> expenses, as set forth in the DIP Budget, which includes the costs and expenses associated with <br /> the continuation of the Debtors' businesses and to maximize the value of the Debtors' assets for <br /> a proposed sale process. <br /> 32 <br />