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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 /> �P ZOZ� SOUTHERN DISTRICT OF OHIO <br /> In re: ) Chapter 11 <br /> Hopedale Mining,LLC,et aL ) 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("Ca=illaz'),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 /> I 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 />