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GENERAL42067
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Last modified
8/24/2016 8:10:34 PM
Creation date
11/23/2007 11:34:37 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977376
IBM Index Class Name
General Documents
Doc Name
MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR ORDER EXTENDING DEBTORS EXCLUSIVE PERIODS TO FILE PLANS
Media Type
D
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, <br /> <br />sigr.ificar.t ne:a car_tal to permit them to update and r„adernize <br />their operations. Even after deterninations are made try Debtors <br />cn Y:c~,; to rescl/e pension liability issues with their z•etirees, <br />employees, ur.icns, and the Pension Benefit Guaranty Coz•poration <br />("PaGC"), and on how to proceed in the reorganization of business <br />operations, creditors and other parties in interest will need <br />substantial time to review and evaluate the proposed resolution <br />of issues by Debtors and to make an informed decision on <br />acceptance or rejection of Debtors' proposals. Therefore, ar. <br />extension of the Exclusive Periods is necessary to afford Debtors <br />the opportunity to complete this process. <br />The bar date for filing claims against Debtors (other than <br />claims by current and former employees arising under a collective <br />bargaining agreement, for which there is currently no bar date) <br />is March 14, 1991. Debtors will likely need a substantial amount <br />of time following this date to review and evaluate claims. <br />D. Debtors' Progress in their Cases to Date Warrants an <br />Exter.sicn of the Exclusive Periods. Aside from the size and <br />complexity of Debtors' cases, an extension of the Exclusive <br />Periods is justified by Debtors' progress in the resolution of <br />issues facing their estates. See, e.a., In re McLean Industries, <br />s:~, 87 Bankr. at 835; In re Texaco, supra, 76 Bankr. at 327; <br />In re Pine Run Trust, supra, 67 Bankr. at 432; In re Swatara Coal <br />Co_, 49 Bankr. 898, 899-900 (Bankr. E.D. Pa. 1985). The record <br />o:E these cases, as outlined in the Motion, demonstrates that <br />Debtors are making substantial progress in resolving i..^..~ortant <br />issues. <br />8 <br />
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