CHAPTER 11 OPERATIONS

final form, at least 24 hours in advance of the hearing. Id. When the petition is filed, the court will contact debtor's counsel and the U.S. Trustee to schedule the hearing. Id.

Any order entered as a result of such a motion or hearing shall be served within two business day on the U.S. Trustee, the list of 20 largest creditors and such other entities as the court directs. DLR 9013-2(d). Any party in interest may file a motion to reconsider any order so entered, within 30 of entry, except for orders for use of cash collateral and approval of postpetition financing. DLR 9013-2(e). Such motions for reconsideration shall be given expedited consideration, and the burden of proof remains with the debtor notwithstanding entry of the initial order. Id.

Any motion pursuant to §§ 363 or 364 must identify the location in the motion of certain kinds of provisions specified in the local rule, and must provide justification for the inclusion of such provision. DLR 4001-2(a)(i). These highlighted provisions include:

1. Cross-collateralization, defined as securing prepetition debt by postpetition assets in which the secured creditor would not otherwise have a security interest.
2. Provisions or findings that bind the estate or all parties in interest with respect to the validity, perfection or amount of a secured creditor's prepetition lien or debt, or waiver of claims against the secured creditor, unless there is 75 days notice and opportunity for parties in interest to investigate, and 60 days for a creditors committee once formed.
3. Provisions waiving the estate's rights to seek surcharge under § 506(c).
4. Provisions immediately granting a prepetition secured creditor liens against the debtor's causes of action arising under §§ 544, 545, 547, 548 and 549.

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