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~r. i <br />E. Debtors' Motive in Reauestina an Extensicn of the <br />Exclusive Periods is to Continue to Make Pro4ress toward <br />Successful Recraanization. Debtors' motive in requesting an <br />extension of the Exclusive Periods is simply to maintain an <br />efficient recrganizaticn process. If the Court were to deny <br />Debtcrs' request for an extension of the Exclusive Periods, any <br />party in interest would be free to propose a plan or plans of <br />reorganization for any or all of Debtors. Although other parties <br />in ir,tzrest mat not, at this early point, come forward with <br />cc~peting plans of reorganization, such an occurrence could have <br />a sicnificant adverse impact on Debtors' business cperations and <br />the progress of these reorganization cases. By fractionalizing <br />the reorganization process, the Court would invite the <br />possibility of a chaotic Chapter 11 environment in which there <br />caould be no central focus of plan negotiations. Debtors' focus <br />caould of necessity be diverted from important reorganization <br />issues. Debtors believe that it is in the best interests of <br />creditors and other parties in interest to have Debtors continue <br />to focus on issues critical to their successful reorganization. <br />Another important reason that the Motion should be granted <br />is that the extensicn of the Exclusive Periods will reduce the <br />likelihood that Debtcrs' cases will become adversarial and <br />improve the likelihood of a negotiated consensual plan or plans <br />of reorganization. As the court in the UNR Industries case <br />noted: <br />[A) negotiated, consensual plan of reorganization <br />is the best route to take. The alternative which <br />right be brought on if the exclusive period were <br />ended could be disastrcus. <br />9 <br />