2020-10-22_GENERAL DOCUMENTS - C1980004 (5)

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Case 1:20-bk-12043 Doc 486 Filed 10/16/20 Entered 10/16/20 10:55:01 Desc Main Document Page 2 of 5 46 BACKGROUND 2. The Debtors commenced these jointly administered chapter 11 cases (the "Chapter I I Cases") by filing voluntary petitions for relief under chapter 11 of title 11 of the United States Code (the "Bankruptcy Code") on July 22, 2020 (the "Petition Date"). A creditors' committee was appointed on July 30, 2020. See Docket No. 128. RELIEF REQUESTED 3. By this Motion, and pursuant to Bankruptcy Rules 9006(b) and 9027(a), the Debtors request an extension of time for the Debtors to file notices of removal (the "Removal Period") of the actions and proceedings in state and federal courts to which the Debtors are parties (the "Actions") through and including February 20, 2021, without prejudice to the Debtors' right to seek further extensions. BASIS FOR RELIEF 4. Section 1452 of title 28 of the United State Code provides for the removal of actions related to bankruptcy cases and provides, in pertinent part: A party may remove any claim or cause of action in a civil action other than a proceeding before the United States Tax Court or a civil action by a governmental unit to enforce such governmental unit's police or regulatory power, to the district court for the district where such civil action is pending, if such district court has jurisdiction of such claim or cause of action under section 1334 of this title. 28 U.S.C. § 1452(a). 5. Bankruptcy Rule 9027 sets forth the time periods for the filing of notices to remove claims or causes of action and provides, in pertinent part: If the claim or cause of action in a civil action is pending when a case under the Code is commenced, a notice of removal may be filed only within the longest of (A) 90 days after the order for relief in the case under the Code, (B) 30 days after entry of an order PA