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Case 1:20-bk-12043 Doc 498 Filed 10/23/20 Entered 10/23/20 08:57:50 Desc Main <br />Document Page 2 of 5 <br />JURISDICTION <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 matter is <br />a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper pursuant to 28 <br />U.S.C. §§ 1408 and 1409. <br />BACKGROUND <br />2. The Debtors commenced these jointly administered chapter 11 cases (the "Chapter <br />11 Cases") by filing voluntary petitions for relief under chapter 11 of title 11 of the United States <br />Code (the `Bankruptcy Code") on July 22, 2020 (the "Petition Date"). A committee of unsecured <br />creditors was appointed in these Chapter 11 Cases on July 30, 2020 (Docket No. 128) (the <br />"Committee") <br />RELIEF REOUESTED <br />3. By this Motion, the Debtors respectfully request, pursuant to section 1121(d) of the <br />Bankruptcy Code, approval of an order whereby: (a) the Filing Exclusivity Period is extended by <br />four (4) months, from November 19, 2020 to and including March 19, 2021, and (b) the Soliciting <br />Exclusivity Period is extended by four (4) months, from January 18, 2021 to and including May <br />18, 2021, without prejudice to the Debtors' right to seek further extensions of the Exclusivity <br />Periods. <br />BASIS FOR RELIEF <br />4. Pursuant to section 1121(b) of the Bankruptcy Code, a debtor has the exclusive <br />right to propose a chapter 11 plan for the first 120 days of a chapter 11 case. 11 U.S.C. § 1121(b). <br />Section 1121(c)(3) of the Bankruptcy Code further extends the period of exclusivity for an <br />additional 60 days, during which the debtor may solicit acceptances of that plan, and no other parry <br />in interest may file a competing plan. 11 U.S.C. § 1121(c)(3). In these Chapter 11 Cases, the <br />2 <br />