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0 <br />Case 1:20-bk-12043 Doc 486 Filed 10/16/20 Entered 10/16/20 10:55:01 Desc Main <br />Document Page 1 of 5 <br />do <br />In re: <br />IN THE UNITED STATES BANKRUPTCY COURT <br />FOR THE SOUTHERN DISTRICT OF OHIO <br />Hopedale Mining LLC, et al.,' <br />Debtors. <br />Chapter 11 <br />Case No. 20-12043 (GRH) <br />(Jointly Administered) <br />rl­�—,?w1.9 E® <br />Honorable Guy R. Humphrey <br />OC I' 2 2 2020 <br />DEBTORS' MOTION FOR ENTRY OF AN ORDER EXTENDING THE <br />TIME WITHIN WHICH THE DEBTORS MAY REMOVE ACTIONS <br />ilECIAMATION <br />,AND SAFETY <br />The above -captioned debtors and debtors in possession (collectively, the "Debtors"), by <br />and through their counsel, respectfully request that this Court enter an order, pursuant to Federal <br />Rules of Bankruptcy Procedure 9006(b) and 9027(a), extending the time for the Debtors to remove <br />actions pending in state and federal courts to which the Debtors are parties, through and including <br />February 20, 2021, without prejudice to the Debtors' right to seek further extensions (this <br />"Motion"). In support of this Motion, the Debtors respectfully state as follows: <br />JURISDICTION AND VENUE <br />1. 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. This is a core <br />proceeding pursuant to 28 U.S.C. § 157(b). Venue is proper pursuant to 28 U.S.C. §§ 1408 and <br />1409. <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 Trucking <br />LLC (8773), Rhino Exploration LLC (8863), Triad Roof Support Systems LLC (1183), Springdale Land LLC (9816), <br />McClane Canyon Mining LLC (3783), Rhino Northern Holdings LLC (1858), CAM -Ohio Real Estate LLC (1859), <br />CAM -Colorado LLC (4269), Taylorville Mining LLC (5106), CAM Coal Trading LLC (4143), Castle Valley Mining <br />LLC (9495), Jewell Valley Mining LLC (0270), Rhino Services LLC (3356), Rhino Oilfield Services LLC (8938), <br />Rhino Technologies LLC (0994), CAM Mining LLC (2498), Rhino Coalfield Services LLC (3924), Hopedale Mining <br />LLC (9060), CAM -Kentucky Real Estate LLC (9089), CAM -BB LLC (9097), Leesville Land LLC (7794), CAM <br />Aircraft LLC (5467), Pennyrile Energy LLC (6095), Rhino Eastern LLC (1457), Rockhouse Land LLC (7702). <br />48374009-5439v1 <br />