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Case 1:20-bk-12043 Doc 441 Filed 09/25/20 Entered 09/25/20 17:20:51 Desc Main <br /> Document Page 6 of 7 <br /> DEBTORS' RESERVATION OF RIGHTS <br /> 14. The Debtors may have claims against contract counterparties arising under, or <br /> independently of, the Rejected Agreements. The Debtors do not waive such claims by the filing <br /> of this Motion or by the rejection of the Rejected Agreements. Furthermore, the Debtors are not <br /> waiving their rights under the Rejected Agreements, including any residual rights the Debtors <br /> may have under any of the Rejected Agreements, whether through insurance coverage or <br /> otherwise. <br /> 15. The Debtors are diligently reviewing and evaluating their remaining contracts and <br /> leases and reserve the right to identify additional executory contracts or unexpired leases for <br /> rejection in the future. This Motion should not be construed as a determination that any contracts <br /> or leases not described in this Motion are to be assumed or rejected. Furthermore, the Debtors <br /> reserve the right to amend this Motion prior to the hearing on this Motion. <br /> 16. Nothing contained in this Motion is intended or should be construed as an <br /> admission of the validity of any claim against the Debtors, a waiver of the Debtors' rights to <br /> dispute any claim, or an approval, assumption, or rejection of any agreement, contract, lease, or <br /> sublease under section 365 of the Bankruptcy Code except as expressly set forth herein. <br /> MOTION PRACTICE <br /> 17. This motion includes citations to the applicable rules and statutory authorities <br /> upon which the relief requested herein is predicated and a discussion of their application to this <br /> motion. Accordingly, the Debtors submit that this motion satisfies Local Rule 9013-1(a). <br /> WHEREFORE, the Debtors respectfully request entry of an order, substantially in the <br /> form attached hereto, granting the relief requested herein and such other relief as is just and <br /> proper. <br /> 6 <br />