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

• Permit No: C1980004
• IBM Index Class Name: General Documents
• Doc Date: 10/22/2020
• Doc Name Note: Case No. 20-12043 ‎(GRH)‎ Hopedale Mining LLC
• Doc Name: Bankruptcy Notice
• From: Epiq Corporate Restructuring, LLC
• To: DRMS
• Permit Index Doc Type: General Correspondence
• Email Name: JRS
• Email Name: JDM
• Email Name: GRM
• Email Name: CMM
• Email Name: CCW
• Media Type: D
• Archive: No

Case 1:20-bk-12043 Doc 486 Filed 10/16/20 Entered 10/16/20 10:55:01 Desc Main `
Document Page 4 of 5
Murray Energy Corporation, Case No. 19-56885 (JEH) (Bankr. S.D. Ohio Oct. 29, 20219)
(Docket No. 838) (extending the debtors' removal deadline 180 days); In re ASPC Corp., No 18-
52736 (JEH) (Bankr. S.D. Ohio Sept. 12, 2018) (granting a 91-day extension of the removal
period); In re Huffy Corp., No. 04-39148 (LSW) (Bankr. S.D. Ohio Jan. 14, 2005) (granting a 180-
day extension of the removal period).
10. The Debtors submit that ample cause exists to extend the Removal Period. Absent
the relief requested herein, the Removal Period will otherwise expire on October 20, 2020. The
Debtors' decision regarding whether to seek removal of any particular Action depends on a number
of factors, including: (a) the importance of the Actions to the resolution of these Chapter 11 Cases;
(b) the time required to complete the Actions in their current venue; (c) the presence of federal
subject matter jurisdiction in the proceeding, which may allow a federal court to hear one or more
aspects thereof; (d) the relationship between the Actions and the matters to be considered in
connection with the Debtors' liquidation process and claims allowance process; and (e) the
progress made to date in the applicable Actions. Accordingly, the Debtors must analyze the
Actions with consideration of the foregoing factors, among others. The extension requested herein
will provide the Debtors with time to make informed decisions concerning which Actions to
remove and will ensure that the Debtors' rights provided by 28 U.S.C. § 1452 can be exercised in
an appropriate manner.
11. Moreover, the rights of parties to the Actions will not be unduly prejudiced by the
Debtors' requested extension of the Removal Period. If the Debtors ultimately seek to remove the
Actions pursuant to Bankruptcy Rule 9027, parties will retain their right to seek remand with
respect to such Actions pursuant to 28 U.S.C. § 1452(b). Therefore, the Debtors submit that cause
exists for the relief requested herein.
4