2020-09-01_GENERAL DOCUMENTS - C1980004 (4)

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UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF OHIO In re: ) Chapter 11 HOPEDALE MINING LLC, et al.,' ) Case No. 20-12043 (GRH) >�. SEIVED Debtors. ) (Jointly Administered) SEP 012020 ",,IV S ON OF RECLAMATION Judge Guy R. Humphrey Pv.JINGAND SAFETY OBJECTION AND RESPONSE OF FGX SPETECH, LLC TO THE DEBTORS' NOTICE OF (A) POTENTIAL ASSUMPTION AND ASSIGNMENT OF EXECUTORY CONTRACTS AND UNEXPIRED LEASES (B) CURE COSTS [DKT. NO. 2361 FGX SepTech, LLC ("FGX") hereby files this objection and response (the "Objection") to Debtors' Notice of (A) Potential Assumption and Assignment of Executory Contracts and Unexpired Leases and (B) Cure Costs (DKT No. 236). In support of its Objection, FGX states as follows: BACKGROUND For good and valuable consideration, on or about March, 22, 2019, Debtor, Castle Valley Mining LLC ("Castle Valley") made, executed, and delivered to FGX, a Sales Agreement (the "Agreement"), under which Castle Valley agreed to pay to FGX certain amounts for One (1) ' The Debtors in these Chapter 11 cases are (with the last four digits of their federal tax identification numbers in parentheses): Rhino GP LLC (8619), Rhino Resource Partners LP (7517), Rhino Energy LLC(6320), Rhino Trucking LLC (8773), Rhino Exploration LLC(8863), Triad Roof Support Systems LLC (1183), Springdale Land LLC (9816), McClane Canyon Mining LLC (3783), Rhino Northern Holdings LLC (1858), CAM -Ohio Real Estate LLC (1859), CAM -Colorado LLC (4269), Taylorville Mining LLC (5106), CAMCoal Trading LLC (4143), Castle Valley Mining LLC (9495), Jewell Valley Mining LLC (0270), Rhino Services LLC (3356), Rhino Oilfield Services LLC (8938), Rhino Technologies LLC (0994), CAMMining LLC (2498), Rhino Coalfield Services LLC (3924), Hopedale Mining LLC (9060), CAM -Kentucky Real Estate LLC (9089), CAM -BB LLC (9097), Leesville Land LLC (7794), CAM Aircraft LLC (5467), Pennyrile Energy LLC (6095), Rhino Eastern LLC (1457), Rockhouse Land LLC (7702).