HDR Holding, Inc.
CASE SUMMARY: Schramm Seeks Going Concern Sale; Affiliate of Prepetition Lender GenNx360 Serving as Stalking Horse, DIP Lender
Mon 06/24/2019 16:15 PM
Relevant Documents:
Voluntary Petition
First Day Declaration
DIP Financing Motion
Bid Procedures Motion
First Day Hearing Agenda
Schramm, a West Chester, Pa.-based hydraulic drill and equipment manufacturer for the oil and gas, mining and water markets, filed for chapter 11 protection today in the Bankruptcy Court for the District of Delaware, along with parent company HDR Holdings. With the support of a $6 million DIP financing commitment from Schramm II, an acquisition vehicle created by 97% shareholder, prepetition lender and stalking horse bidder GenNx360, the case was filed to effectuate a sale of substantially all of the debtors’ assets as a going concern. The debtors and GenNx360 entered into an asset purchase agreement prepetition that contemplates a purchase price of “not less than” $10.3 million, plus the balance owing under the DIP facility, consisting of a credit bid and the assumption of certain liabilities.” The debtors propose an Aug. 13 bid deadline and an Aug. 19 sale hearing.
In the first day declaration of HDR CEO Craig Mayman, the debtors say that, while they believe that they have a viable business, their current capital structure is unsustainable. Based on preliminary indications of interest, “it is possible that a sale transaction may not generate sufficient proceeds to cover the full amount of the Debtors’ current secured debt,” the debtors caution.
The first day hearing is set for Tuesday, June 25, at 2 p.m. ET.
The company attributes the bankruptcy to their failure to meet revenue projections and maintain compliance with covenants under prepetition credit facilities. Noting its exposure to the oil and gas industry, Schramm says that it has grappled with the industry’s prolonged reduction in drilling operations for several years and the consequent drop in demand for the debtors’ products and services. The debtors have shifted focus to the mining sector, which they say is “steadier,” and the sale of aftermarket equipment and refurbished rigs. These strategic shifts, along with efforts to conserve cash in anticipation of an oil market recovery, boosted revenue from 2016 to 2017 and improved EBITDA in 2018, but the company’s financial performance “has continued to be strained,” with the primary hurdles to success consisting of “macroeconomic issues outside of their control and the Debtors’ unsustainable capital structure.”
The company reports $50 million to $100 million in both assets and liabilities, including “not less than” approximately $20 million in secured debt.
The debtors entered into a $72 million secured credit facility with Citizens Bank as agent in June 2012. The parties entered into various forbearance agreements pursuant to which GenNx360 Capital Partners, L.P., the holder of 97% of the equity of HDR, lent the debtors $2 million, and subsequently, an additional $4 million. In March 2016, the debtors, Enhanced Credit Supported Loan Fund (now known as Hark Capital) and the lenders (including Citizens and GenNx360) entered into an amended and restated credit agreement, through which Hark (a) acquired debt issued under the 2012 loan agreement in the outstanding principal amount of $20.6 million, (b) agreed to forgive an amount of the loans under the original loan agreement to reduce the outstanding amount of such loans held by Hark to $12.3 million and (c) agreed to make an additional term loan to the debtors in the amount of $1.2 million.
The amounts owed to Hark ($12.3 million plus $1.2 million) constitute first-priority term loan A obligations under the amended credit agreement. GenNx360 executed a guaranty of the debtors’ term loan A obligations in favor of Hark. In addition, GenNx360 agreed to forgive its $4 million loan and to acquire loans issued under the 2012 loan agreement in the outstanding principal amount of $6.5 million, which obligation constitutes a second priority term loan B under the amended credit agreement, junior to the term loan A obligations owed to Hark under the amended credit agreement. Citizens, on behalf of certain of the lenders under the 2012 loan agreement, agreed to forgive an amount of the remaining loans under the original loan agreement to reduce the outstanding amount of such loans to $6 million (which remaining obligation constitutes a third priority term loan C under the amended credit agreement) and were issued warrants. This month, under the terms of the guaranty, GenNx360 made an $11 million payment to Hark in partial satisfaction of the term loan A.
While pursuing sale and refinancing alternatives in the eight months leading up to the chapter 11 filing, the debtors relied on cash infusions from GenNx360. Absent a clear path to an out-of-court restructuring transaction that would satisfy its secured indebtedness, GenNx360 was unwilling to continue funding the debtors’ business. Consequently, the debtors determined to launch a marketing process for a sale of the business through chapter 11. In order to preserve the company’s going concern value, the debtors require further funding, which GenNx360 has agreed to lend in the form of a $6 million delayed-draw term loan promissory note.
The debtors are represented by Young Conaway Stargatt & Taylor as counsel and FocalPoint Partners as investment banker. Epiq is the claims agent. The case has been assigned to Judge Mary F. Walrath (case number 19-11396).
Background
Founded in West Chester, Pa., in 1900 as an industrial equipment manufacturer, Schramm produces and sells a variety of mobile, top-head hydraulic rotary drilling rigs that are mounted on trucks, tracks and trailers used primarily in the mining, oil and gas and water end-markets. Schramm’s products are sold “on every continent,” and the company maintains “major” market positions in China, Australia, Russia, Latin America and Africa. The debtors also sell consumable drill parts required for the operation of its rigs and other ancillary equipment and perform rig repair services.
HDR is a holding company and the direct parent of Schramm, which is the direct parent of non-debtor Schramm Australia Holding Pty Limited, which is the direct parent of two Australian non-debtor affiliates (Airdrill Pty Ltd and Airdrill Hammers and Bits Pty Ltd), which manufacture and sell drills in the Australian market and manufacture hammers and bits for Schramm drills. Schramm Australia and its subsidiaries “are not parties to these Chapter 11 Cases or any case seeking protection from their creditors,” and the debtors say that the operations of Schramm Australia are contemplated to continue in the ordinary course.
The debtors' largest unsecured creditors are listed below:
The case representatives are as follows:
Bid Procedures Motion/Sale Process
The debtors say that they have been exploring a sale or refinancing over the past eight months through FocalPoint Partners, which contacted 146 strategic and financial investors. Two parties submitted non-binding term sheets, one of which sought to structure a transaction solely involving the acquisition of the debtors’ secured debt along with some contingent consideration. According to the debtors, though the other party originally contemplated a cash investment, along with a restructuring of the secured debt,“after further diligence and discussions, this interested party indicated it would be only willing to provide such investment in connection with an acquisition of the secured term loan debt which it would use to bid on the Debtors’ assets in a court-supervised sale process.” Both interested parties ultimately determined to “pass on the investment opportunity.”
As funds dwindled and no third-party acquirer emerged with a concrete proposal to satisfy their secured obligations and continue the business as a going concern, the debtors were “faced with the specter of immediately ceasing operations, laying off their remaining employees, and beginning a liquidation process.”
According to the bid procedures motion, the stalking horse purchase price is $10.3 million plus the balance owing under the proposed DIP facility, estimated at $6 million, in the form of a credit bid plus the “assumption of certain liabilities.” Initial overbids are $100,000 (for a minimum competing opening bid of $16.4 million), and a deposit equal to 10% of the purchase price is required.
The purchased assets include avoidance actions arising from or related to any contract or other obligation that will be assumed and assigned to the purchaser as part of the sale, as well as all equity in Schramm Australia.
The assumed liabilities include cure amounts and post-closing liabilities under assumed contracts and permits arising from and after the closing date, all unpaid accounts payable arising after the petition date in the ordinary course, and allowed section 503(b)(9) claims for delivery of goods within 20 days prior to the petition date.
The bid procedures motion also proposes that the stalking horse bidder would offer employment to all employees, including management, at the same base salary or hourly wage received by such employees immediately prior to closing.
Liabilities excluded from the transaction include, among other things, taxes, professional fees and expenses, and debts and liabilities of Schramm Australia at the time of closing.
The debtors propose the following sale timeline:
DIP Financing Motion /Cash Collateral Motion
The debtors request approval of $6 million in DIP financing from stalking horse bidder Schramm II in the form of a delayed-draw term loan promissory note, with interim access of up to $3 million. The company also seeks approval to use Hark and GenNx360’s cash collateral “subject to the terms and limitations set forth in the Interim Order.”
The DIP financing bears interest at 12%, with an additional 2% for the default rate of interest, and matures 120 days after the petition date. The DIP proceeds may be used to fund working capital requirements, costs and expenses of administration of the chapter 11 cases and fees and expenses relating to the DIP facility.
In support of the proposed DIP financing, the debtors filed the declaration of FocalPoint’s Michael Fixler, who states that “given the Debtors’ current projections and their relative lack of unencumbered assets, immediate access to the DIP Facility and use of cash collateral is necessary for the Debtors’ continued operations, including to pay critical expenses such as wages, salaries, and benefits, to procure necessary goods and services (and maintain trade terms with the Debtors’ vendors), to finance the costs of these Chapter 11 Cases, and to meet certain other working capital needs.”
Further, according to the debtors, “[d]uring the course of restructuring negotiations, it became clear that the Debtors’ prepetition secured lenders would not agree to be primed by a third-party lender. Given the Debtors’ desire to avoid the cost and uncertainty of a postpetition DIP financing facility that would attempt to non-consensually prime the Debtors’ prepetition secured lenders, the Debtors and their advisors concluded that, under the circumstances, acceptable third-party financing was not reasonably obtainable.”
To secure the DIP financing, the debtors propose to grant a first priority, priming lien on all encumbered property of the debtors and their estates that would be senior to any existing liens or claims and junior only to the carveout and certain permitted senior liens. The motion says that the debtors “do not expect the Interim Order to provide for any non-consensual priming of Hark, GenNx360, or the Agent other than with respect to the Carve-Out.” Pursuant to the final order, the debtors also propose to grant liens on the proceeds of avoidance actions.
The DIP agreement contains affirmative and negative covenants “in form and substance customary for debtor-in-possession financing of this type such as the Approved Budget and Permitted Variances (as defined therein) and taking into account the specific transaction, subject to, where appropriate, carve-outs and exceptions to be agreed.”
Adequate Protection
The company proposes adequate protection to the prepetition secured parties in the form of junior security interests and replacement liens (which would be subordinate to the carveout, the DIP obligations, the DIP liens, the DIP superpriority claims and the permitted senior liens), superpriority administrative expense claims and “customary admissions and stipulations with respect to the amounts outstanding under the Prepetition Financing Documents, the validity, perfection, enforceability and priority of liens and security interests securing the obligations under the Prepetition Financing Documents, the non-existence of any grounds for the Debtors to challenge any aspect of the Prepetition Financing Documents and the obligations thereunder or the respective holders thereof and a release by the Debtors with respect to the foregoing.”
In addition, the debtors propose a waiver of the estates’ right to seek to surcharge its collateral pursuant to Bankruptcy Code section 506(c) and the “equities of the case” exception under section 552(b).
The carveout for fees and expenses of retained professionals, the CRO and official unsecured creditors committee is $50,000.
DIP Budget
The proposed budget for the use of the DIP facility is HERE.
DIP Milestones
The DIP financing is subject to the following milestones:
Other Motions
The debtors also filed various standard first day motions, including the following:
Voluntary Petition
First Day Declaration
DIP Financing Motion
Bid Procedures Motion
First Day Hearing Agenda
| Summary |
| HDR Holding, through operating subsidiary Schramm, manufactures and sells hydraulic drills and equipment for the oil and gas, mining and water end-markets |
| Attributes bankruptcy to oil market downturn’s negative impact on the demand for Schramm’s services and “unsustainable” capital structure |
| Seeks going concern sale for substantially all assets to acquisition vehicle created by prepetition secured lender GenNx360, which also proposes to provide debtors with $6 million DIP financing facility |
Schramm, a West Chester, Pa.-based hydraulic drill and equipment manufacturer for the oil and gas, mining and water markets, filed for chapter 11 protection today in the Bankruptcy Court for the District of Delaware, along with parent company HDR Holdings. With the support of a $6 million DIP financing commitment from Schramm II, an acquisition vehicle created by 97% shareholder, prepetition lender and stalking horse bidder GenNx360, the case was filed to effectuate a sale of substantially all of the debtors’ assets as a going concern. The debtors and GenNx360 entered into an asset purchase agreement prepetition that contemplates a purchase price of “not less than” $10.3 million, plus the balance owing under the DIP facility, consisting of a credit bid and the assumption of certain liabilities.” The debtors propose an Aug. 13 bid deadline and an Aug. 19 sale hearing.
In the first day declaration of HDR CEO Craig Mayman, the debtors say that, while they believe that they have a viable business, their current capital structure is unsustainable. Based on preliminary indications of interest, “it is possible that a sale transaction may not generate sufficient proceeds to cover the full amount of the Debtors’ current secured debt,” the debtors caution.
The first day hearing is set for Tuesday, June 25, at 2 p.m. ET.
The company attributes the bankruptcy to their failure to meet revenue projections and maintain compliance with covenants under prepetition credit facilities. Noting its exposure to the oil and gas industry, Schramm says that it has grappled with the industry’s prolonged reduction in drilling operations for several years and the consequent drop in demand for the debtors’ products and services. The debtors have shifted focus to the mining sector, which they say is “steadier,” and the sale of aftermarket equipment and refurbished rigs. These strategic shifts, along with efforts to conserve cash in anticipation of an oil market recovery, boosted revenue from 2016 to 2017 and improved EBITDA in 2018, but the company’s financial performance “has continued to be strained,” with the primary hurdles to success consisting of “macroeconomic issues outside of their control and the Debtors’ unsustainable capital structure.”
The company reports $50 million to $100 million in both assets and liabilities, including “not less than” approximately $20 million in secured debt.
The debtors entered into a $72 million secured credit facility with Citizens Bank as agent in June 2012. The parties entered into various forbearance agreements pursuant to which GenNx360 Capital Partners, L.P., the holder of 97% of the equity of HDR, lent the debtors $2 million, and subsequently, an additional $4 million. In March 2016, the debtors, Enhanced Credit Supported Loan Fund (now known as Hark Capital) and the lenders (including Citizens and GenNx360) entered into an amended and restated credit agreement, through which Hark (a) acquired debt issued under the 2012 loan agreement in the outstanding principal amount of $20.6 million, (b) agreed to forgive an amount of the loans under the original loan agreement to reduce the outstanding amount of such loans held by Hark to $12.3 million and (c) agreed to make an additional term loan to the debtors in the amount of $1.2 million.
The amounts owed to Hark ($12.3 million plus $1.2 million) constitute first-priority term loan A obligations under the amended credit agreement. GenNx360 executed a guaranty of the debtors’ term loan A obligations in favor of Hark. In addition, GenNx360 agreed to forgive its $4 million loan and to acquire loans issued under the 2012 loan agreement in the outstanding principal amount of $6.5 million, which obligation constitutes a second priority term loan B under the amended credit agreement, junior to the term loan A obligations owed to Hark under the amended credit agreement. Citizens, on behalf of certain of the lenders under the 2012 loan agreement, agreed to forgive an amount of the remaining loans under the original loan agreement to reduce the outstanding amount of such loans to $6 million (which remaining obligation constitutes a third priority term loan C under the amended credit agreement) and were issued warrants. This month, under the terms of the guaranty, GenNx360 made an $11 million payment to Hark in partial satisfaction of the term loan A.
While pursuing sale and refinancing alternatives in the eight months leading up to the chapter 11 filing, the debtors relied on cash infusions from GenNx360. Absent a clear path to an out-of-court restructuring transaction that would satisfy its secured indebtedness, GenNx360 was unwilling to continue funding the debtors’ business. Consequently, the debtors determined to launch a marketing process for a sale of the business through chapter 11. In order to preserve the company’s going concern value, the debtors require further funding, which GenNx360 has agreed to lend in the form of a $6 million delayed-draw term loan promissory note.
The debtors are represented by Young Conaway Stargatt & Taylor as counsel and FocalPoint Partners as investment banker. Epiq is the claims agent. The case has been assigned to Judge Mary F. Walrath (case number 19-11396).
Background
Founded in West Chester, Pa., in 1900 as an industrial equipment manufacturer, Schramm produces and sells a variety of mobile, top-head hydraulic rotary drilling rigs that are mounted on trucks, tracks and trailers used primarily in the mining, oil and gas and water end-markets. Schramm’s products are sold “on every continent,” and the company maintains “major” market positions in China, Australia, Russia, Latin America and Africa. The debtors also sell consumable drill parts required for the operation of its rigs and other ancillary equipment and perform rig repair services.
HDR is a holding company and the direct parent of Schramm, which is the direct parent of non-debtor Schramm Australia Holding Pty Limited, which is the direct parent of two Australian non-debtor affiliates (Airdrill Pty Ltd and Airdrill Hammers and Bits Pty Ltd), which manufacture and sell drills in the Australian market and manufacture hammers and bits for Schramm drills. Schramm Australia and its subsidiaries “are not parties to these Chapter 11 Cases or any case seeking protection from their creditors,” and the debtors say that the operations of Schramm Australia are contemplated to continue in the ordinary course.
The debtors' largest unsecured creditors are listed below:
| 10 Largest Unsecured Creditors | |||
| Creditor | Location | Claim Type | Amount |
|---|---|---|---|
| DNOW L.P. | Houston | Litigation | $ 5,560,888 |
| Hydro Air Hughes, LLC | Philadelphia | Trade | 312,239 |
| Doosan Infracore Portable Power |
Chicago | Trade | 300,000 |
| Leiss Tool & Die | Somerset, PA | Trade | 240,032 |
| General Engineering Company |
Abingdon, VA | Trade | 213,598 |
| Den-Con Tool Company |
Oklahoma City | Trade | 179,317 |
| Sullivan Palatek | Detroit | Trade | 178,023 |
| Exploration Drill Masters Chile S.A. |
Santiago, Chile | Trade | 173,120 |
| Cordicate IT | Blue Bell, PA | Trade | 168,063 |
| BDO USA, LLP | Philadelphia | Professional Services |
144,275 |
The case representatives are as follows:
| Representatives | |||
| Role | Name | Firm | Location |
|---|---|---|---|
| Debtors' Counsel | Pauline K. Morgan | Young Conaway Stargatt & Taylor |
Wilmington, DE |
| Sean T. Greecher | |||
| Joseph M. Mulvihill | |||
| Jared W. Kochenash | |||
| Debtors' Investment Banker |
Michael Fixler | FocalPoint Partners |
Chicago |
| Co-Counsel for GenNx360 / Schramm II |
Carey D. Schreiber | Winston & Strawn | New York |
| Co-Counsel for GenNx360 / Schramm II |
Jamie Edmonson | Robinson & Cole | Wilmington, DE |
| Counsel for the Prepetition Secured Parties and Agent |
Jordan Kroop | Perkins Coie | Phoenix |
| U.S. Trustee | Linda Casey | Office of the U.S. Trustee |
Wilmington, DE |
| Debtors' Claims Agent | Kathryn Tran | Epiq | New York |
Bid Procedures Motion/Sale Process
The debtors say that they have been exploring a sale or refinancing over the past eight months through FocalPoint Partners, which contacted 146 strategic and financial investors. Two parties submitted non-binding term sheets, one of which sought to structure a transaction solely involving the acquisition of the debtors’ secured debt along with some contingent consideration. According to the debtors, though the other party originally contemplated a cash investment, along with a restructuring of the secured debt,“after further diligence and discussions, this interested party indicated it would be only willing to provide such investment in connection with an acquisition of the secured term loan debt which it would use to bid on the Debtors’ assets in a court-supervised sale process.” Both interested parties ultimately determined to “pass on the investment opportunity.”
As funds dwindled and no third-party acquirer emerged with a concrete proposal to satisfy their secured obligations and continue the business as a going concern, the debtors were “faced with the specter of immediately ceasing operations, laying off their remaining employees, and beginning a liquidation process.”
According to the bid procedures motion, the stalking horse purchase price is $10.3 million plus the balance owing under the proposed DIP facility, estimated at $6 million, in the form of a credit bid plus the “assumption of certain liabilities.” Initial overbids are $100,000 (for a minimum competing opening bid of $16.4 million), and a deposit equal to 10% of the purchase price is required.
The purchased assets include avoidance actions arising from or related to any contract or other obligation that will be assumed and assigned to the purchaser as part of the sale, as well as all equity in Schramm Australia.
The assumed liabilities include cure amounts and post-closing liabilities under assumed contracts and permits arising from and after the closing date, all unpaid accounts payable arising after the petition date in the ordinary course, and allowed section 503(b)(9) claims for delivery of goods within 20 days prior to the petition date.
The bid procedures motion also proposes that the stalking horse bidder would offer employment to all employees, including management, at the same base salary or hourly wage received by such employees immediately prior to closing.
Liabilities excluded from the transaction include, among other things, taxes, professional fees and expenses, and debts and liabilities of Schramm Australia at the time of closing.
The debtors propose the following sale timeline:
DIP Financing Motion /Cash Collateral Motion
The debtors request approval of $6 million in DIP financing from stalking horse bidder Schramm II in the form of a delayed-draw term loan promissory note, with interim access of up to $3 million. The company also seeks approval to use Hark and GenNx360’s cash collateral “subject to the terms and limitations set forth in the Interim Order.”
The DIP financing bears interest at 12%, with an additional 2% for the default rate of interest, and matures 120 days after the petition date. The DIP proceeds may be used to fund working capital requirements, costs and expenses of administration of the chapter 11 cases and fees and expenses relating to the DIP facility.
In support of the proposed DIP financing, the debtors filed the declaration of FocalPoint’s Michael Fixler, who states that “given the Debtors’ current projections and their relative lack of unencumbered assets, immediate access to the DIP Facility and use of cash collateral is necessary for the Debtors’ continued operations, including to pay critical expenses such as wages, salaries, and benefits, to procure necessary goods and services (and maintain trade terms with the Debtors’ vendors), to finance the costs of these Chapter 11 Cases, and to meet certain other working capital needs.”
Further, according to the debtors, “[d]uring the course of restructuring negotiations, it became clear that the Debtors’ prepetition secured lenders would not agree to be primed by a third-party lender. Given the Debtors’ desire to avoid the cost and uncertainty of a postpetition DIP financing facility that would attempt to non-consensually prime the Debtors’ prepetition secured lenders, the Debtors and their advisors concluded that, under the circumstances, acceptable third-party financing was not reasonably obtainable.”
To secure the DIP financing, the debtors propose to grant a first priority, priming lien on all encumbered property of the debtors and their estates that would be senior to any existing liens or claims and junior only to the carveout and certain permitted senior liens. The motion says that the debtors “do not expect the Interim Order to provide for any non-consensual priming of Hark, GenNx360, or the Agent other than with respect to the Carve-Out.” Pursuant to the final order, the debtors also propose to grant liens on the proceeds of avoidance actions.
The DIP agreement contains affirmative and negative covenants “in form and substance customary for debtor-in-possession financing of this type such as the Approved Budget and Permitted Variances (as defined therein) and taking into account the specific transaction, subject to, where appropriate, carve-outs and exceptions to be agreed.”
Adequate Protection
The company proposes adequate protection to the prepetition secured parties in the form of junior security interests and replacement liens (which would be subordinate to the carveout, the DIP obligations, the DIP liens, the DIP superpriority claims and the permitted senior liens), superpriority administrative expense claims and “customary admissions and stipulations with respect to the amounts outstanding under the Prepetition Financing Documents, the validity, perfection, enforceability and priority of liens and security interests securing the obligations under the Prepetition Financing Documents, the non-existence of any grounds for the Debtors to challenge any aspect of the Prepetition Financing Documents and the obligations thereunder or the respective holders thereof and a release by the Debtors with respect to the foregoing.”
In addition, the debtors propose a waiver of the estates’ right to seek to surcharge its collateral pursuant to Bankruptcy Code section 506(c) and the “equities of the case” exception under section 552(b).
The carveout for fees and expenses of retained professionals, the CRO and official unsecured creditors committee is $50,000.
DIP Budget
The proposed budget for the use of the DIP facility is HERE.
DIP Milestones
The DIP financing is subject to the following milestones:
- Bid procedures motion: filed by June 27
- Interim DIP order: entered by June 27
- Bid procedures order: entered by July 19
- Final DIP order: entered by July 24
- Sale order: entered by Aug. 28
- Sale closing: by Sept. 3
The debtors also filed various standard first day motions, including the following:
- Motion for Joint Administration
- The cases will be jointly administered under case no. 19-11396.
- Motion to Pay Critical Vendors
- The debtors seek to pay critical vendors up to $1.269 million on an interim basis and $1.692 million on a final basis. The debtors also propose that all critical vendor payments be applied first to any claims entitled to administrative expense priority under section 503(b)(9) of the Bankruptcy Code or good received by the debtors within 20 days of the petition date.
- Motion to Pay Employee Wages and Benefits
- HDR requests authority to pay employee obligations on an interim basis in the approximate amounts:
- Motion to Use Cash Management System
- The company has bank accounts with PNC Bank.
- Motion to Maintain Insurance Programs
- Motion to Pay Taxes and Fees
- The debtors estimate that as of the petition date, they owe up to $40,000 in taxes and fees in the aggregate, comprised entirely of current tax obligations and not “catch-up” payments.
- Motion to Continue Customer Programs
- Motion to Provide Utilities with Adequate Assurance
- Application to Appoint Epiq as Claims Agent
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