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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
Archive
No
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<br /> <br />procedure for a hearing on a motion brought under section 364 of <br />the Bankruptcy Code: <br />The court may commence a final hearing on a motion <br />for authority to obtain credit no earlier than 15 days <br />after service of the motion. If the motion so <br />requests, the court may conduct a hearing before such <br />15 day period expires, but the court may authorize the <br />obtaining of credit only to the extent necessary to <br />avoid immediate and irreparable harm to the estate <br />pending a final hearing. <br />Most of these cases on postpetition financing involve <br />prepetition lenders providing postpetition financing and, thus, <br />include controversial provisions such as cross-collateralization <br />and surrender of certain rights by the estate relating to the <br />prepetition loans. Other cases involve priming existing lenders. <br />In spite of these complications, these courts authorized <br />postpetition financing to permit the debtors to remain in <br />business. These complicating factors sometimes attendant to a <br />prepetition lender providing postpetition financing are not <br />present in the cases of the Debtors. The Court should authorize <br />final financing to permit the Debtors to remain viable. <br />In In re Antico Manufacturing Co.. Inc. 31 Bankr. 103, 104 <br />(Bankr. E.D.N.Y. 1983), the court, following a hearing heald on <br />the petition date on notice to the debtor's ten largest <br />creditors, authorized the debtor to borrow up to $200,000 on an <br />interim basis to revive the debtor's business operations, which <br />had been shut down prior to the petition date. The interim <br />financing was secured by a lien on certain assets and received a <br />superpriority under section 364(c)(1). Thereafter, the court <br />held a final hearing on notice to all creditors at which time it <br />6 <br />
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