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Case 1:20-bk-12043 Doc 628 Filed 03/02/21 Entered 03/02/21 11:09:01 Desc Main <br />Document Page 9 of 10 <br />thereafter as is practicable if due on or before that date and unpaid on the Effective <br />Date, (ii) as soon as practicable after the date upon which such Administrative <br />Claim becomes an Allowed Claim, or (iii) such other date as may be agreed upon <br />between the Holder of such Allowed Administrative Claim and the Liquidating <br />Trustee. <br />[Plan, p. 13.] Under that provision, Caterpillar is entitled to payment of its Allowed Administrative <br />Claim as soon as practicable after the date upon which it becomes an Allowed Claim. Accordingly, <br />Caterpillar requests that the Court authorize and direct the Liquidating Trustee to pay Caterpillar <br />the full amount of its Allowed Administrative Claim within ten (10) days of entry of an order <br />granting this Application. <br />WHEREFORE, Caterpillar respectfully requests that the Court enter an order: (a) granting <br />this Application; (b) determining that Caterpillar has an Allowed Administrative Claim (as that <br />term is defined in and used in the Plan) in the amount of $254,987.75; (c) authorizing and directing <br />the Liquidating Trustee to pay Caterpillar the full amount of the Allowed Administrative Claim <br />within ten (10) days after entry of the order; and (d) granting Caterpillar such other and further <br />relief as the Court deems just and proper. <br />Dated: March 2, 2021 Respectfully submitted, <br />/s/ Amelia M. Adams <br />Gregory D. Pavey (admitted pro hac vice) <br />KY Bar No. 81049 <br />Amelia M. Adams (admitted pro hac vice) <br />KY Bar No. 93038 <br />300 West Vine Street, Suite 2100 <br />Lexington, Kentucky 40507-1801 <br />(859) 231-3000 <br />gregory.pavey@skofirm.com <br />amelia.adams@skofirm.com <br />Counsel for Caterpillar Financial <br />Services Corporation <br />0 <br />