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GENERAL44158
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GENERAL44158
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Last modified
8/24/2016 8:12:59 PM
Creation date
11/23/2007 12:52:30 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977376
IBM Index Class Name
General Documents
Doc Name
MEMORANDUM IN SUPPORT OF MOTION OF DEBTORS FOR ORDER AUTHORIZING FINANCING GRANTING SENIOR LIENS &
Media Type
D
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No
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<br /> <br />showing that they have made reasonable efforts to obtain <br />unsecured debt. In re Ames Dent. Stores, 115 Bankr. at 37 <br />(S. D.N.Y. 1990) (the debtor must make an effort to find <br />alternative credit sources, but it is not required to seek credit <br />from every possible lender). The pension liability owed by the <br />Debtors is daunting, however, and lenders have been unwilling <br />even to consider lending on an unsecured basis. Thus, it is <br />clear that the Debtors must borrow funds on a secured and <br />superpriority basis. <br />There is no explicit requirement in section 364 (c) that a <br />' debtor needs to shop for the best loan terms for a loan on a <br />secured or superpriority basis, but some cases require a debtor <br />to do so. See, e.a., In re Ames Deot. Stores, 115 Bankr. at 37- <br />38 (a debtor's discretion in deciding what terms to agree to is <br />not "unbridled," but the court should permit the debtor in <br />possession "to exercise [its] basic business judgment consistent <br />with [its] fiduciary duties"). As noted in the Motion, for the <br />past several years, the Debtors have sought financing from <br />numerous lenders. The Debtors, using their business judgment, <br />believe that the terms of the financing proposed in the Motion <br />from Congress are as good as the Debtors can possibly expect to <br />receive and are better than terms that have been proposed by <br />other lenders the Debtors have contacted. <br />Bankruptcy Rule 4001(c) governs the procedures necessary to <br />incur financing. Subsection (2) of this rule sets forth the <br />5 <br />
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