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c , <br />,2 <br />B. The Tire Necessary to Terminate Debtors' Pension Plan <br />Ftiii °_xceed the Initial 120-day Period. As outlined in the <br />t^.cticn, Debtcrs cannot propose a plan of reorganization crithcut <br />first !:awing their pension plan terminated. The procedures <br />necessary to have their pension plan terminated will take more <br />ti-e than the initial 120-day period in tese cases. <br />C. At this Preliminary Point in D=_btors' Chanter 11 <br />Cases, the Recuested Extension of the Exclusive Periods is <br />~llStlf'_°_'~ b~: the S=Ze and CorplexltV Of De~tcrs' Cases Alor.e. ~5 <br />of the date of this memorandum, Debtors' Chapter 11 cases have <br />been pending fcr fe:aer than ninety days. See In re RCiI II, <br />supra, 118 Bankr. at 464 (denying leave tc appeal from order <br />extending exclusivity period, "this is the first extension in a <br />fcur-month-old case"). The requested extensions of the Exclusive <br />Periods are well within the limits of extensions granted by <br />courts in other cases involving much smaller, less complex <br />debtors and issues. Indeed, in a number o_° cases involving large <br />Chapter 11 debtors with pension issues si-:ilar to those in these <br />cases, the debtors' exclusive periods remained in effect for <br />several years, such as the LTV cases, in which the exclusive <br />periods have been extended over four years. <br />The size and complexity of Debtors' businesses, corporate <br />structure, and financing support the requested extension. Under <br />the circumstances of these cases Debtors cannot formulate, <br />promulgate, and built a consensus to support a plan within the <br />initial exclusivity period provided in 11 U.S.C. § 1121. <br />5 <br />