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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 2 of 8 <br />PRELIMINARY STATEMENT <br />1. Since the commencement of these chapter 11 cases, the Debtors have worked to <br />market their assets and effectuate value -maximizing sales of substantially all of their assets. <br />These efforts culminated in eight value -maximizing sale transactions that were approved by this <br />Court pursuant to the Order (I) Approving the Sale of Substantially dll of the Debtors' Assets <br />Free and Clear of All Non -Assumed Liens, Claims, Encumbrances, and Interests; (II) Approving <br />the Assumption and Assignment of Certain Executory Contracts and Unexpired Leases; and (III) <br />Granting Related Relief (Docket No. 410) (the "Sale Order").3 <br />2. While the Debtors explored alternative options to bring these chapter 11 cases to a <br />conclusion, at this time the Debtors believe that the chapter 7 conversion contemplated by this <br />Motion is the most expeditious and cost-effective mechanism to wind down the Debtors' affairs <br />and these Chapter 11 Cases. In reaching this conclusion, the Debtors determined that a <br />conversion to chapter 7 would provide the best outcome for creditors (as opposed to a chapter 11 <br />liquidating plan) because, following the closing of the Sale Transaction, the Debtors' only <br />remaining assets will be certain estate actions, which have not been monetized. The Debtors also <br />face the potential reality of administrative insolvency. As a result, at this time, the Debtors do not <br />believe that a chapter 11 plan is feasible or in the best interests of their creditors. <br />3. Accordingly, the Debtors respectfully request that this Court enter the Conversion <br />Order granting the conversion of these Chapter 11 Cases to chapter 7 and grant the related relief <br />on the terms set forth therein. <br />JURISDICTION AND VENUE <br />4. The United States Bankruptcy Court for the Southern District of Ohio (this <br />"Court") has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334. Venue is <br />s Capitalized terms used herein but undefined shall have the meanings ascribed to them in the Sale Order. <br />2 <br />