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r <br /> <br />IndUSLr'_e5, Si:~°a, 87 Sankt. at $33i In re SOUth:JeSt Oil, SL'Dra, <br />8~ Ba.^,r.=. at ,~1-52; In re Wisconsin Barce Line. Inc., 78 Bar.::r. <br />94'0, 9~8 (Sankt. E.D. Mo. 1987); In re Pine Run Trust, Inc., 67 <br />Banks. 432, 435 (Bankr. E.D. Pa. 1986); In re United Press Int'1. <br />Tic., 60 Bankr. 265, 269 (Bankr. D.C. 1986); 5 Collier on <br />Bankructcv g 1121.04 at 1121-14 (15th ed. 1990); In re American <br />Federation of i'elevision and Radio Artists, 30 Bankr. 772, 774 <br />(Bankr. S.D.tI.Y. 1983) (legislative history indicates that "an <br />unusually large case" is itself cause for an extensicn). <br />Courts have referred to cases substantially smaller than <br />Debtors' cases as "large and complex." Fcr exa-ple, the debtor <br />in the L'PI case was a $40 million company requiring a <br />multimillicn dollar line of credit, a variety of insurance <br />coverages, and worldwide telecommunicaticns services. 60 Bar,Y.r. <br />at 269. In granting a third extension of the debtor's <br />exclusivity, the court in that case observed that "[i]n many -uch <br />smaller cases, involving far less complications, two or three <br />}'ears go by before the debtor is in a position to file a plan." <br />Id. at 270. See also In re Perkins, suar=_, 71 Bankr. at 296 (100 <br />cr~3itors held 225 claims amounting to $10,000,000 against estate <br />valued at $13,000,000; case "unusually large and complex"). <br />The size and complexity of Debtors' Chapter 11 cases pose <br />a number of practical issues which, at this time, prevent <br />formulation of a meaningful plan of reorcanization. For example, <br />as outlined above and in the Motion, Debtors will not be able to <br />propcse a confirmable plan of reorganization until their pension <br />plan is terminated. They must also seek the infusion of <br />7 <br />