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Case 1:20-bk-12043 Doc 436 Filed 09/18/20 Entered 09/18/20 15:58:33 Desc Main <br />Document Page 1 of 8 <br />IN THE UNITED STATES BANKRUPTCY COURT <br />FOR THE SOUTHERN DISTRICT OF OHIO <br />In re: ) Chapter 11 <br />Hopedale Mining LLC, et al.,' ) Case No. 20-12043 (GRH) <br />(Jointly Administered) <br />Debtors. ) Honorable Guy R. Humphrey <br />DEBTORS' MOTION FOR ENTRY OF AN ORDER CONVERTING THEIR CHAPTER <br />11 CASES TO CASES UNDER CHAPTER 7 AND APPROVING CERTAIN MATTERS <br />RELATED THERETO, INCLUDING ESTABLISHING PROCEDURES RELATED TO <br />FINAL FEE APPLICATIONS FOR THESE CHAPTER 11 CASES <br />The above -captioned debtors and debtors in possession (collectively, the "Debtors") file <br />this Motion seeking entry of an order, substantially in the form attached hereto as Exhibit A (the <br />"Conversion Order"): (i) converting each of the Debtors' Chapter 11 Cases (as defined in this <br />Motion) to cases under chapter 7 of the Bankruptcy Code effective as of October 13, 2020 (the <br />"Conversion Date"); and (ii) approving certain other procedures related to conversion, including <br />procedures related to the filing of final fee applications by Professionals (the "Conversion <br />Procedures ,).2 In support of this motion, the Debtors respectfully state as follows: <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 <br />Trucking LLC (8773), Rhino Exploration LLC (8863), Triad Roof Support Systems LLC (1183), Springdale Land <br />LLC (9816), McClane Canyon Mining LLC (3783), Rhino Northern Holdings LLC (1858), CAM -Ohio Real Estate <br />LLC (1859), CAM -Colorado LLC (4269), Taylorville Mining LLC (5106), CAM Coal Trading LLC (4143), Castle <br />Valley Mining LLC (9495), Jewell Valley Mining LLC (0270), Rhino Services LLC (3356), Rhino Oilfield Services <br />LLC (8938), Rhino Technologies LLC (0994), CAM Mining LLC (2498), Rhino Coalfield Services LLC (3924), <br />Hopedale Mining LLC (9060), CAM -Kentucky Real Estate LLC (9089), CAM -BB LLC (9097), Leesville Land <br />LLC (7794), CAM Aircraft LLC (5467), Pennyrile Energy LLC (6095), Rhino Eastern LLC (1457), Rockhouse <br />Land LLC (7702). <br />2 "Professionals" means all professionals retained by the Debtors or the Committee pursuant to sections 327, 328, or <br />1102 of the Bankruptcy Code. <br />