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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 6 of 8 <br />version of all imaged claims; (ii) upload the creditor mailing list into <br />CM/ECF; (iii) docket a final claims register in the Debtors' Chapter 11 <br />Cases; and (iv) box and transport all original claims to the Dayton Federal <br />Records Center, 3150 Springboro Road, Moraine, Ohio 45439, and docket <br />a completed SF-135 Form indicating the accession and location numbers <br />of the archived claims. Upon compliance with these procedures, on the <br />Conversion Date, Epiq Corporate Restructuring shall be relieved of its <br />responsibilities as the Debtors' claims and noticing agent in the Debtors' <br />Chapter 11 Cases and will have no further obligations to the Court, the <br />Debtors, the chapter 7 trustee (once appointed), or any party in interest <br />with respect to the Debtors' Chapter 11 Cases or the chapter 7 cases. <br />Furthermore, Epiq is authorized to shred or otherwise dispose of all <br />noticing and other documents that have been returned by the post office as <br />undeliverable mail. <br />BASIS FOR RELIEF <br />10. Section 1112(a) of the Bankruptcy Code provides that a debtor may convert a <br />case to chapter 7 as a matter of right. See H.R_ Rep. No. 95-595, lst Sess. 405 (1977) <br />("Subdivision (a) gives the debtor an absolute right to convert a voluntarily commenced chapter <br />11 case in which the debtor remains in possession to a liquidation case."); S. Rep. No 95-989, <br />95th Cong., 2d Sess. 117 (1978) (same). Several courts have concluded that, absent certain <br />exceptions contained in section 1112(a) of the Bankruptcy Code that are noted below, a debtor <br />has an absolute right to convert its chapter 11 case to a case under chapter 7 of the Bankruptcy <br />Code. See Tex. Extrusion Corp. v. Lockheed Corp. (In re Tex. Extrusion Corp), 844 F.2d 1142 <br />(5th Cir. 1988) (noting that "a debtor has the absolute right to convert [its] Chapter 11 case to a <br />Chapter 7 case"); Sept. 27, 2017 Hr'g Tr. at 35:12-15, In re Constellation Enters. LLC, Case No. <br />16-11213 (CSS) (Bankr. D. Del. Sept. 27, 2017) ("I find and rule that the debtors have an <br />absolute right to convert these [chapter II] cases."). Nevertheless, courts in the Sixth Circuit <br />have concluded that a bankruptcy court can deny a debtor's conversion from chapter 11 to <br />chapter 7 if "extreme circumstances such as bad faith" exist. In re Johnson, 546 B.R. 83, 160 <br />(Bankr. S.D. Ohio 2016) (quoting In re Adler, 329 B.R. 406, 409 (Bankr S.D. N.Y. 2005) and <br />rel <br />