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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 4 of 5 <br />Order (I) Approving the Sale of Substantially All of the Debtors'Assets Free and Clear ofAll Non - <br />Assumed Liens, Claims, Encumbrances, and Interests; (II) Approving the Assumption and <br />Assignment of Certain Executory Contracts and Unexpired Leases; and (III) Granting Related <br />Relief (Docket No. 410) (the "Sale Order"). Since the entry of the Sale Order, and as discussed <br />on the record at the hearing held before this Court on October 13, 2020, the Debtors have been <br />focusing on the best path forward in connection with these Chapter 11 Cases while being mindful <br />of estate resources and potential recoveries to creditors. During this time, the Debtors, the <br />Committee, the Prepetition Lenders, and the DIP Lenders have reached a global resolution (the <br />"Lender Settlement"), which is more particularly described in the Joint Motion of the Debtors <br />and the Official Committee of Unsecured Creditors for Approval of Settlement Agreement with <br />Prepetition Lenders and DIP Lenders Pursuant to Bankruptcy Rule 9019 (Docket No. 483) (the <br />"Lender Settlement Motion"). <br />8. The Lender Settlement requires, among other things, the Debtors to pursue <br />confirmation of a chapter 11 plan (the "Plan") while providing the Debtors' estates with an <br />additional $400,000 to $500,000 in proceeds. The Debtors believe that this is the best path forward <br />for these Chapter 11 Cases and the Debtors intend to seek confirmation of a joint Plan with the <br />Committee as promptly as possible. However, the current Exclusivity Periods will likely expire <br />before the Debtors and the Committee will be able to confirm a Plan. Therefore, out of an <br />of caution, the Debtors seek a brief but reasonable extension of the Exclusivity Periods <br />allow the Debtors to effectuate the Lender Settlement and to seek confirmation of a Plan. <br />Capitalized but undefined terms used in this paragraph shall have the meanings ascribed to them in the Lender <br />ettlement Motion. <br />4 <br />