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Case 1:20-bk-12043 Doc 303 Filed 08/28/20 Entered 08/28/20 11:03:45 Desc Main <br />Document Page 12 of 13 <br />(e) assert a claim for allowance of administrative expenses under section 503 of the Bankruptcy <br />Code. <br />WHEREFORE, Wintrust respectfully requests that this Court enter an order providing: (a) <br />this Objection is sustained; (b) if the Lease Agreement is not assumed by the purchaser at closing <br />on the sale of the Debtors' assets, it is deemed rejected as of the closing date; (c) upon such <br />rejection, the Debtors shall execute such lease termination documents as are reasonably requested <br />by Wintrust and the automatic stay is terminated with respect to the Wintrust Equipment pursuant <br />to Section 365(p) of the Bankruptcy Code to permit Wintrust to remarket the Wintrust Equipment <br />from its current locations for a period of 180 days with no liability to Wintrust for storage or similar <br />charges; (d) alternatively, if the Lease Agreement is to be assumed by the purchaser, (i) the correct <br />cure cost, including attorneys' fees and expenses, shall be paid to Wintrust on or before closing, <br />(ii) all Unliquidated Obligations shall be cured prior to, or survive the assumption and assignment, <br />and that any assignee shall undertake to satisfy all monetary and non -monetary obligations under <br />the Lease Agreement, regardless of whether such obligations existed, occurred, or accrued prior <br />to the assumption and assignment of the Lease Agreement, and (iii) the Debtors shall provide <br />adequate assurance of future performance under the Lease Agreement prior to the assumption and <br />assignment thereof, and (e) Wintrust shall be granted such other and further relief as this Court <br />deems just and proper under the circumstances. <br />12 <br />