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Case 1:20-bk-12043 Doc 307 Filed 08/28/20 Entered 08/28/20 16:03:37 Desc Main <br />Document Page 1 of 10 <br />UNITED STATES BANKRUPTCY COURT <br />SOUTHERN DISTRICT OF OHIO <br />In re: ) Chapter II <br />Hopedale Mining, LLC, et al. i ) Case No. 1:20-bk-12043 (GRH) <br />Jointly Administered <br />Debtors ) <br />Honorable Guy R. Humphrey <br />CATERPILLAR FINANCIAL SERVICES CORPORATION'S <br />OBJECTION TO DEBTORS' NOTICE OF CURE COSTS AND RESERVATION <br />OF RIGHTS AS TO ADEQUATE ASSURANCE OF FUTURE PERFORMANCE <br />UNDER LEASES [ECF NO. 2361 AND RESERVATION OF RIGHTS AS TO <br />SALE OF DEBTORS' ASSETS [ECF NO. 261 <br />Comes Caterpillar Financial Services Corporation ("Caterpillar"), by counsel and pursuant <br />to 11 U.S.C. §§ 363 and 365, and all other applicable law, and for (1) its objection to the Debtors' <br />Notice of (A) Potential Assumption and Assignment of Executory Contracts and Unexpired Leases <br />and (B) Cure Costs and the schedule of cure costs contained therein [ECF No. 236 ("Cure Cost <br />Notice")] and related reservation of rights as to adequate assurance of future performance under <br />certain leases between Debtor Rhino Energy, LLC and Caterpillar, and (2) its reservation of rights <br />as to any sale of the Debtors' assets as contemplated in the Motion for Entry of (I) an Order (A) <br />Approving Bidding and Sale Procedures with Respect to the Sale of Substantially All of the <br />Debtors' Assets, (B) Authorizing the Entry into the Asset Purchase Agreement with the Stalking <br />The Debtors in these Chapter 11 cases are (with the last four digits of their federal tax identification numbers in <br />parentheses): Rhino GP LLC (8619), Rhino Resource Partners LP (7517), Rhino Energy LLC (6320), Rhino Trucking <br />LLC (8773), Rhino Exploration LLC (8863), Triad Roof Support Systems LLC (1183), Springdale Land LLC (9816), <br />McClane Canyon Mining LLC (3783), Rhino Northern Holdings LLC (1858), CAM -Ohio Real Estate LLC (1859), <br />CAM -Colorado LLC (4269), Taylorville Mining LLC (5106), CAM Coal Trading LLC (4143), Castle Valley Mining <br />LLC (9495), Jewell Valley Mining LLC (0270), Rhino Services LLC (3356), Rhino Oilfield Services LLC (8938), <br />Rhino Technologies LLC (0994), CAM Mining LLC (2498), Rhino Coalfield Services LLC (3924), Hopedale Mining <br />LLC (9060), CAM -Kentucky Real Estate LLC (9089), CAM -BB LLC (9097), Leesville Land LLC (7794), CAM <br />Aircraft LLC (5467), Pennyrile Energy LLC (6095), Rhino Eastern LLC (1457), Rockhouse Land LLC (7702). <br />