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2020-08-28_GENERAL DOCUMENTS - C1980004 (6)
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2020-08-28_GENERAL DOCUMENTS - C1980004 (6)
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Last modified
12/28/2024 4:34:52 AM
Creation date
9/16/2020 8:39:59 AM
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DRMS Permit Index
Permit No
C1980004
IBM Index Class Name
General Documents
Doc Date
8/28/2020
Doc Name Note
Case No. 20-12043 (GRH) Hopedale Mining LLC
Doc Name
Objection of Wintrust Commercial Finance to Sale Motion
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Permit Index Doc Type
General Correspondence
Email Name
JRS
JDM
GRM
CMM
CCW
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D
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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 11 of 13 <br /> assumption and assignment, (b) provide that any and all Unliquidated Obligations shall be cured <br /> at or prior to assumption and assignment or survive the assumption and assignment, and that any <br /> assignee shall take the Lease Agreement subject to all of its respective terms and undertake to <br /> satisfy all monetary and non-monetary obligations under the Lease Agreement, regardless of <br /> whether such obligations could be argued to have existed, occurred, or accrued prior to the <br /> assumption and assignment of the Lease Agreement. <br /> 19. Finally, the Debtors have not provided adequate assurance of future performance <br /> within the meaning of section 365(b)(1)(C) of the Bankruptcy Code regarding any potential <br /> assumption and assignment of the Lease Agreement including, regarding not only the payment of <br /> all the monetary obligations under the Lease Agreement but also the performance of all <br /> Unliquidated Obligations. In accordance with the provisions of the Notice of Cure Costs,Wintrust <br /> requests that the Debtors provide information to establish any proposed purchaser's ability to <br /> perform under the Lease Agreement, and Wintrust objects to the approval of any assignment <br /> thereof absent such information. <br /> RESERVATION OF RIGHTS <br /> 20. Nothing in this Objection is intended to be, or should be construed as, a waiver by <br /> Wintrust of any of its rights under the Lease Agreement, the Bankruptcy Code, or applicable law. <br /> Wintrust expressly reserves all such rights including, without limitation, the right to: (a) <br /> supplement and/or amend this Objection to assert any additional objections with respect to the Sale <br /> Motion, the Notice of Cure Costs and/or any proposed assumption and assignment of the Lease <br /> Agreement; (b) amend the cure cost under the Lease Agreement; (c) assert any additional <br /> unliquidated obligations and/or nonmonetary defaults under the Lease Agreement; (d) object to <br /> the ability of any proposed purchaser to provide adequate assurance of future performance; and <br /> 11 <br />
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