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Full title: Motion for Continuation of Utility Service and Approval of Adequate Assurance of Payment to Utility Company Under Section 366(b) Filed by Debtor The Prospect-Woodward Home (Attachments: # 1 Exhibit A # 2 Exhibit B) (Graham, Owen) (Entered: 08/30/2021)

Document posted on Aug 29, 2021 in the bankruptcy, 30 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

By this Motion, the Debtor seeks entry of interim and final orders: (a) prohibiting the Utility Providers from altering, refusing, or discontinuing service on account of unpaid prepetition invoices; (b) determining that, pursuant to Bankruptcy Code section 366, adequate assurance of payment for postpetition utility services has been furnished to the Utility Providers; and (c) approving the Additional Adequate Assurance Procedures (as defined below) as the method for resolving future requests by any Utility Provider for additional adequate assurance of payment.Additional Assurance Request by mutual agreement with the requesting Utility Provider without further notice to the Court or any other party in interest, and may, in connection with any such agreement, provide a Utility Provider with additional adequate assurance of future payment, including, but not limited to, cash deposits, prepayments, letters of credit, and/or other forms of security, without further order of the Court to the extent that the Debtor believes such additional assurance is reasonable in the exercise of its business judgment and the Debtor may, by mutual agreement with the objecting Utility Provider and without further order of the Court, reduce the Adequate Assurance Deposit by an amount not exceeding the requesting Utility Provider’s estimated two-week utility expense; f. The Debtor may supplement the Utility Providers List without further order of the Court with Additional Utility Providers if such Additional Utility Providers were inadvertently omitted from the Utility Providers List, and the Debtor will file as soon as practicable with the Court a supplement to Exhibit 1 attached hereto that adds the name of any Additional Utility Provider to the Utility Providers List.Additional Assurance Request by mutual agreement with the requesting Utility Provider without further notice to the Court or any other party in interest, and may, in connection with any such agreement, provide a Utility Provider with additional adequate assurance of future payment, including, but not limited to, cash deposits, prepayments, letters of credit, and/or other forms of security, without further order of the Court to the extent that the Debtor believes such additional assurance is reasonable in the exercise of its business judgment and the Debtor may, by mutual agreement with the objecting Utility Provider and without further order of the Court, reduce the Adequate Assurance Deposit by an amount not exceeding the requesting Utility Provider’s estimated two-week utility expense; e. The Debtor may supplement the Utility Providers List without further order of the Court with Additional Utility Providers if such Additional Utility Providers were inadvertently omitted from the Utility Providers List, and the Debtor will file as soon as practicable with the Court a supplement to Exhibit 1 annexed to the Interim Order that adds the name of any Additional Utility Provider to

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF NEW HAMPSHIRE In re: ) Chapter 11 ) The Prospect-Woodward Home, ) Case No. 21-10523-BAH ) Debtor.1 ) ) EMERGENCY EX PARTE MOTION OF DEBTOR FOR ENTRY OF INTERIM AND FINAL ORDERS (I) PROHIBITING UTILITY PROVIDERS FROM ALTERING, REFUSING, OR DISCONTINUING SERVICE, (II) APPROVING THE DEBTOR’S PROPOSED ADEQUATE ASSURANCE OF PAYMENT FOR POSTPETITION SERVICES, AND (III)ESTABLISHING PROCEDURES FOR RESOLVING REQUESTS FOR ADDITIONAL ADEQUATE ASSURANCE OF PAYMENT The above-captioned debtor (“Hillside Village” or the “Debtor”) hereby moves (this “Motion”) pursuant to sections 105(a) and 366 of title 11 of the United States Code (the “Bankruptcy Code”), and Rules 6003 and 6004 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) for the entry of interim and final orders (i) prohibiting Utility Providers (as defined below) from altering, refusing, or discontinuing service, (ii) determining that adequate assurance of payment for postpetition utility services has been furnished to the Utility Providers, and (iii) establishing procedures for resolving future requests for additional adequate assurance. In support of the Motion, the Debtor relies upon the Declaration of Toby Shea, Chief Restructuring Officer, in Support of the Debtor’s First Day Pleadings (the “First Day Declaration”) filed with the Court contemporaneously herewith. In further support of the Motion, the Debtor respectfully represents as follows: 1 The last four digits of the Debtor’s federal taxpayer identification are 2146. The address of the Debtor’s headquarters is 95 Wyman Road, Keene, New Hampshire 03431

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JURISDICTION AND VENUE 1. This Court has jurisdiction to consider this Motion pursuant to 28 U.S.C. §§ 157 and 1334. This is a core proceeding under 28 U.S.C. § 157(b). 2. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 3. The statutory predicates for the relief requested herein are Bankruptcy Code sections 105 and 366 and Bankruptcy Rules 6003 and 6004. BACKGROUND I. General Background 4. On the date hereof (the “Petition Date”), the Debtor commenced this case by filing a voluntary petition for relief under chapter 11 of the Bankruptcy Code (the “Chapter 11 Case”). 5. The factual background regarding the Debtor, including business operations, capital and debt structure, and the events leading to the filing of the Chapter 11 Case is set forth in the First Day Declaration and incorporated herein by reference. 6. The Debtor continues to operate and manage its business as a debtor in possession pursuant to Bankruptcy Code sections 1107 and 1108. 7. No trustee, examiner, or creditors’ committee has been appointed in the Chapter 11 Case. II. Description of Utility Services and Utility Providers 8. In connection with its day-to-day operations, the Debtor receives traditional utility services from approximately 10 utility providers (each a “Utility Provider” and collectively, the “Utility Providers”). The Utility Providers are identified on Exhibit 1 to Exhibit A hereto (the “Utility Service List”). The Debtor paid an average of approximately $64,000 per month on account of utility services during the trailing twelve months (“TTM”) ended July 31, 2021. As detailed in the First Day Declaration, the Debtor anticipates needing the services of the Utility

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Providers going forward to maintain operations of the continuing care retirement facility known as Hillside Village. RELIEF REQUESTED 9. Bankruptcy Code section 366 prohibits a utility company, within the first 30 days after the filing of a chapter 11 case, from altering, refusing, or discontinuing services to, or discriminating against, a debtor solely on the basis of the commencement of bankruptcy proceedings or the debtor’s failure to pay a prepetition debt. In a chapter 11 case, once the initial 30 days have expired, a utility company may discontinue services if the debtor has not provided the utility company with “adequate assurance of payment for utility service that is satisfactory to the utility.” 11 U.S.C. § 366(c)(2). 10. By this Motion, the Debtor seeks entry of interim and final orders: (a) prohibiting the Utility Providers from altering, refusing, or discontinuing service on account of unpaid prepetition invoices; (b) determining that, pursuant to Bankruptcy Code section 366, adequate assurance of payment for postpetition utility services has been furnished to the Utility Providers; and (c) approving the Additional Adequate Assurance Procedures (as defined below) as the method for resolving future requests by any Utility Provider for additional adequate assurance of payment. I. Proposed Adequate Assurance 11. Consistent with Bankruptcy Code section 366(c)(1)(A), which defines the phrase “assurance of payment” to include, among other things, a cash deposit, and given the relatively de minimis amount of the funds required, the Debtor proposes to segregate on its books and records, within twenty (20) days of the Petition Date, an amount equal to the estimated cost for two weeks of Utility Services (i.e., approximately $30,000.00), calculated based on the historical data for TTM 7/31/2021 (the “Adequate Assurance Deposit”) into one segregated bank account designated for the Adequate Assurance Deposit (the “Adequate Assurance Deposit Account”) for the benefit

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of all Utility Providers. Thus, to maintain uninterrupted Utility Services, the Debtor proposes to deposit $30,000.00 into the Adequate Assurance Deposit Account within 20 days of the Petition Date. Thereafter, the Debtor proposes to adjust the amount in the Adequate Assurance Deposit Account to reflect several factors: (a) the termination of Utility Services by the Debtor regardless of any Additional Assurance Requests (as defined below), and (b) agreements reached with Utility Providers. These adjustments will permit the Debtor to maintain the Adequate Assurance Deposit Account with an amount that consistently provides the Utility Providers with a half-month deposit on account of such services. 12. The Debtor submits that the Adequate Assurance Deposit and maintenance of the Adequate Assurance Deposit Account as described above, in conjunction with the Debtor’s ability to pay for future utility services in the ordinary course of business (together, the “Proposed Adequate Assurance”), constitutes sufficient adequate assurance of future payment to the Utility Providers to satisfy the requirements of Bankruptcy Code section 366. However, if any Utility Provider believes additional assurance is required, they may request such assurance pursuant to the procedures described below. II. Proposed Adequate Assurance Procedures 13. In light of the severe consequences to the Debtor of any interruption in services by the Utility Providers, but recognizing the right of each Utility Provider to evaluate the Proposed Adequate Assurance on a case-by-case basis, the Debtor requests that the Court approve, and allow the Debtor to implement, the following procedures (the “Adequate Assurance Procedures”) by which a Utility Provider not satisfied with the Proposed Adequate Assurance may request additional adequate assurance (an “Additional Assurance Request”): a. Within two (2) business days of the date the Interim Order is docketed, the Debtor will mail a copy of the Interim Order to the Utility Providers on the Utility Providers List;

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b. If a Utility Provider is not satisfied with the Proposed Adequate Assurance and seeks additional assurance of payment in the form of a deposit, letter of credit, prepayment, or otherwise, it must serve an Additional Assurance Request upon (i) proposed counsel to the Debtor (a) Polsinelli PC, 600 Third Avenue, 42nd Floor, New York, New York 10016, Attn: Jeremy R. Johnson (jeremy.johnson@polsinelli.com) and Attn: Stephen J. Astringer (sastringer@polsinelli.com); and (b) Hinckley, Allen & Snyder LLP, 650 Elm Street, Manchester, New Hampshire 03101, Attn: Daniel M. Deschenes (ddeschenes@hinckleyallen.com) and 28 State Street, Boston, Massachusetts 02109, Attn: Jennifer V. Doran (jdoran@hinckleyallen.com); (ii) counsel to UMB Bank, as indenture trustee (the “Bond Trustee”), Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., One Financial Center, Boston, Massachusetts 02111, Attn: Daniel S. Bleck (dsbleck@mintz.com); (iii) the Office of the United States for the District of New Hampshire; and (iv) counsel to any official committee appointed in the Chapter 11 Case (together, the “Notice Parties”); c. Each Additional Assurance Request must (i) be made in writing; (ii) set forth all location(s) for which utility services are provided and the relevant account number(s); (iii) include a summary of the Debtor’s payment history relevant to the affected account(s); (iv) describe any deposits or other security currently held by the requesting Utility Provider; and (v) identify and explain the basis of the Utility Provider’s proposed adequate assurance requirement under Bankruptcy Code section 366(c)(2); d. Upon the Notice Parties’ receipt of an Additional Assurance Request at the addresses set forth in subparagraph (b) above, the Debtor shall promptly negotiate with such Utility Provider to resolve such Utility Provider’s Additional Assurance Request; e. The Debtor may, in its discretion and in consultation with the Bond Trustee, resolve an Additional Assurance Request by mutual agreement with the requesting Utility Provider without further notice to the Court or any other party in interest, and may, in connection with any such agreement, provide a Utility Provider with additional adequate assurance of future payment, including, but not limited to, cash deposits, prepayments, letters of credit, and/or other forms of security, without further order of the Court to the extent that the Debtor believes such additional assurance is reasonable in the exercise of its business judgment and the Debtor may, by mutual agreement with the objecting Utility Provider and without further order of the Court, reduce the Adequate Assurance Deposit by an amount not exceeding the requesting Utility Provider’s estimated two-week utility expense;

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f. If the Debtor determines that a timely received Additional Assurance Request is not reasonable and is unable to reach an alternative resolution with the applicable Utility Provider within 30 days of the date the Additional Assurance Request was made, or such later date to which the Debtor and the applicable Utility Provider agree, the Debtor shall, upon reasonable notice, calendar the matter (the “Adequate Assurance Dispute”) for the next regularly scheduled omnibus hearing to determine the adequacy of assurance of payment pursuant to Bankruptcy Code section 366(c)(3); g. Pending resolution of any such Adequate Assurance Dispute, any such Utility Provider shall be prohibited from altering, refusing, or discontinuing service to the Debtor on account of unpaid charges for prepetition services, the filing of the Chapter 11 Case, or any objection to the adequacy of the Proposed Adequate Assurance; and h. Upon the termination of Utility Services, the Debtor may, in its discretion and upon fourteen (14) days’ notice to the parties in interest, Notice Parties, and all affected Utility Providers, reduce the Adequate Assurance Deposit by an amount not exceeding, for each of the Utility Services being discontinued, the lesser of (a) the estimated two-week utility expense for such Utility Services and (b) the amount of the Adequate Assurance Deposit then attributable to the applicable Utility Provider, provided that there are no outstanding disputes related to postposition amounts due. III. Subsequent Modification of the Utility Providers List 14. The Debtor requests that it be allowed, without further order of the Court, to supplement the Utility Providers List if any Utility Provider has been inadvertently omitted therefrom (each an “Additional Utility Provider”). If the Debtor determines that the Utility Providers List should be supplemented, the Debtor will, as soon as practicable, file with the Court a supplement to Exhibit A-1 adding the name of any Additional Utility Provider to the Utility Providers List. The Debtor will then serve by email or by facsimile transmission (or, where the Debtor does not have the email address or fax number of a Utility Provider, by First Class Mail) a copy of this Motion and the signed Interim or Final Order, as applicable, on any Additional Utility Provider.

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IV. Request for a Final Hearing 15. The Debtor requests that a final hearing on this Motion be held within thirty (30) days of the Petition Date to ensure that, if a Utility Provider argues it may unilaterally refuse service to the Debtor on the 31st day after the Petition Date, the Debtor will have an opportunity, to the extent necessary, to request that the Court make such modifications to the Adequate Assurance Procedures in time to avoid any potential termination of Utility Services. 16. The Debtor further requests that the Court set a final hearing (the “Final Hearing”), if necessary, within thirty (30) days of the Petition Date. BASIS FOR RELIEF REQUESTED 17. Congress enacted Bankruptcy Code section 366 to protect a debtor from immediate termination of utility services after filing for bankruptcy, while at the same time providing the utility companies with adequate assurance of payment for postpetition utility services. See H R. Rep. No. 95-595, at 350 (1977), reprinted in 1978 U.S.C.C.A.N. 5963, 6306. Bankruptcy Code Section 366 defines “assurance of payment” to mean several forms of security, including cash deposits, letters of credit, and prepayment of utility services. 11 U.S.C. § 366(c)(1)(A). Bankruptcy Code Section 366(c)(1)(B) explicitly excludes, however, offering administrative expense priority as adequate assurance of payment. Further, Bankruptcy Code section 366(c) restricts the factors that a court may consider when determining whether the “assurance of payment” is, in fact, adequate. Specifically, courts may no longer rely on (a) the absence of a security deposit before the debtor’s petition date, (b) the debtor’s history of timely payments, or (c) the availability of an administrative expense priority when determining the amount of a deposit. See Id. § 366(c)(3)(B). 18. Although Bankruptcy Code section 366(c) sets forth what constitutes adequate assurance of payment, the bankruptcy court nonetheless retains discretion to determine what, if any, adequate assurance is necessary to satisfy section 366’s requirement that assurance of

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payment must only be “adequate.” See In re Adelphia Bus. Solutions, Inc., 280 B.R. 63, 80 (Bankr. S.D.N.Y. 2002) (“The bankruptcy courts are in agreement that section 366(b) vests in the bankruptcy court the exclusive responsibility for determining the appropriate security which a debtor must provide to his utilities to preclude termination of service for nonpayment of prepetition utility bills.”); In re Circuit City Stores, 2009 WL 484553, at *4 (Bankr. E.D. Va. 2009) (stating that courts have discretion under section 366(c) to determine the amount of adequate payments or collateral required to a utility company); In re Begley, 41 B.R. 402, 405-06 (E.D. Pa. 1984), aff’d, 760 F.2d 46 (3d Cir. 1985). Accordingly, a court is not required to give the utility companies an “absolute guarantee of payment,” or require that the adequate assurance take the form of a deposit, bond, letter of credit, or similar security. In re Caldor, Inc. -NY, 199 B.R. 1, 3 (S.D.N.Y. 1996), aff’d sub nom., Va. Elec. & Power Co. v. Caldor, Inc., 117 F.3d 646 (2d Cir. 1997); In re Great Atl. & Pac. Tea Co., 2011 WL 5546954, at *5 (Bankr. S.D.N.Y. 2011) (finding that “[c]ourts will approve an amount that is adequate enough to insure against unreasonable risk of nonpayment, but are not required to give the equivalent of a guaranty of payment in full”). 19. Rather, in considering the facts and circumstances of each case, the Court must ensure only that the utility is not subject to an unreasonable risk of non-payment for postpetition services. See In re Adelphia, 280 B.R. at 80; Mass. Elec. Co. v. Keydata Corp. (In re Keydata Corp.), 12 B.R. 156, 158 (B.A.P. 1st Cir. 1981). The Court, therefore, must strike a balance between satisfying the utility company’s need for adequate assurance and ensuring that the debtor gives no more than what is adequate, as the debtor has a conflicting need to conserve financial resources. See In re Magnesium Corp. of Am., 278 B.R. 698, 714 (Bankr. S.D.N.Y. 2002) (holding that to require the debtor to allocate valuable liquidity to provide further “adequate assurance” to

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satisfy a utility’s obligations before its amount has been fixed would prejudice the entirety of the debtor’s unsecured creditor body for the benefit of a single one). 20. In determining whether a utility is subject to an unreasonable risk of nonpayment, the Court may consider whether the utility would seek the same additional security from a non-bankruptcy customer. See In re Caldor, Inc. -NY, 199 B.R. at 3 (finding that the utility companies were not seeking additional security for an adequate assurance of future payment, but solely because their monopoly position permitted them to capitalize on the debtor bankruptcy filing); Whittaker v. Phila. Elec. Co. (In re Whittaker), 84 B.R. 934, 937, 941-42 (Bankr. E D. Pa. 1988), aff’d, 882 F.2d 791 (3d Cir. 1989) (finding utility company violated Bankruptcy Code section 366 when it refused to restore debtor’s electric service, upon notice of bankruptcy filing, without prepayment of deposit as adequate assurance of future payment). I. The Debtor’s Proposed Adequate Assurance is Routinely Upheld as Adequate by Courts 21. Because this Court is afforded the discretion to determine the assurance necessary to satisfy the Utility Providers’ needs, the Debtor submits that the Proposed Adequate Assurance is more than adequate to ensure that the Debtor will meet its postpetition utility obligations. 22. The Debtor’s receipt of uninterrupted Utility Services is vital to the Debtor’s continued business operations and, consequently, to the success of this Chapter 11 Case. Accordingly, the relief requested herein is necessary and in the best interests of the Debtor, the estate, and creditors. Such relief ensures that the Debtor’s business operations will not be disrupted and provides Utility Companies and the Debtor with an orderly and fair procedure for determining “adequate assurance.” 23. Based upon the foregoing, the Debtor submits that the relief requested herein should be granted.

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II. Bankruptcy Rule 6003 Has Been Satisfied and Bankruptcy Rule 6004 Should Be Waived 24. Certain isolated aspects of the relief requested herein may, if granted, be subject to Bankruptcy Rule 6003. Pursuant to Bankruptcy Rule 6003, a court may grant such relief if it is necessary to avoid immediate and irreparable harm. The Debtor submits that the facts set forth herein demonstrate the relief requested is necessary to avoid immediate and irreparable harm to the Debtor and, thus, Bankruptcy Rule 6003 has been satisfied. Additionally, to the extent that any aspect of the relief sought herein constitutes a use of property under Bankruptcy Code section 363(b), the Debtor seeks a waiver of the fourteen-day stay under Bankruptcy Rule 6004(h). As described above, the relief that the Debtor seeks in this Motion is immediately necessary in order for the Debtor to be able to continue to operate and preserve the value of the estate. The Debtor thus submits that the requested waiver of the fourteen-day stay imposed by Bankruptcy Rule 6004(h) is appropriate. WAIVER OF MEMORANDUM OF LAW 25. The Debtor requests that the Court waive and dispense with the requirement set forth in LBR 7102(b)(2) that any motion filed shall have an accompanying memorandum of law. The legal authorities upon which the Debtor relies are set forth in the Motion. Accordingly, the Debtor submits that a waiver of the requirements set forth in LBR 7102(b)(2) is appropriate under the circumstances. NOTICE 26. Notice of the Motion has been provided to: (a) the Office of the United States Trustee for the District of New Hampshire; (b) counsel to the New Hampshire Insurance Department; (c) the United States Attorney’s Office for the District of New Hampshire; (d) counsel

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to UMB Bank, as indenture trustee; (e) the Debtor’s twenty (20) largest unsecured creditors; (f) the Utility Providers; and (g) any party filing a notice of appearance in this Chapter 11 Case. 27. The Debtor submits that, in light of the nature of the relief requested, no further notice of this Motion is required. NO PRIOR REQUEST 28. No prior request for the relief sought herein has been made to this Court or any other court.

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WHEREFORE, the Debtor respectfully requests entry of interim and final orders, substantially in the forms attached hereto as Exhibit A and Exhibit B, granting the relief requested herein and granting such other relief as is just and proper. Dated: August 30, 2021 /s/ Owen R. Graham HINCKLEY, ALLEN & SNYDER LLP Daniel M. Deschenes (Bar No. 14889) Owen R. Graham (Bar No. 266701) 650 Elm Street Manchester, New Hampshire 03101 Telephone: (603) 225-4334 Facsimile: (603) 224-8350 ddeschenes@hinckleyallen.com -and- Jennifer V. Doran (Pro Hac Vice Pending) 28 State Street Boston, Massachusetts 02109 Telephone: (617) 345-9000 Facsimile: (617) 345-9020 jdoran@hinckleyallen.com -and- POLSINELLI PC Jeremy R. Johnson (Pro Hac Vice Pending) Stephen J. Astringer (Pro Hac Vice Pending) 600 Third Avenue, 42nd Floor New York, New York 10016 Telephone: (212) 684-0199 Facsimile: (212) 684-0197 jeremy.johnson@polsinelli.com sastringer@polsinelli.com Proposed Counsel to the Debtor and Debtor in Possession

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Exhibit A Proposed Interim Order

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF NEW HAMPSHIRE In re: ) Chapter 11 ) Prospect-Woodward Home, ) Case No. 21-______ (____) ) Debtor. 1 ) Re: Docket No. _____ ) INTERIM ORDER (I) PROHIBITING UTILITY PROVIDERS FROM ALTERING, REFUSING, OR DISCONTINUING SERVICE, (II) APPROVING THE DEBTOR’S PROPOSED ADEQUATE ASSURANCE OF PAYMENT FOR POSTPETITION SERVICES, AND (III) ESTABLISHING PROCEDURES FOR RESOLVING REQUESTS FOR ADDITIONAL ADEQUATE ASSURANCE OF PAYMENT FOR POSTPETITION SERVICES, AND (III) ESTABLISHING PROCEDURES FOR RESOLVING REQUESTS FOR ADDITIONAL ADEQUATE ASSURANCE OF PAYMENT Upon the Emergency Ex Parte Motion of Debtor for Entry of Interim and Final Orders (I) Prohibiting Utility Providers from Altering, Refusing, or Discontinuing Service, (II) Approving the Debtor’s Proposed Adequate Assurance of Payment for Postpetition Services, and (III) Establishing Procedures for Resolving Requests for Additional Adequate Assurance of Payment for Postpetition Services, and (III) Establishing Procedures for Resolving Requests for Additional Adequate Assurance of Payment (the “Motion”)2 of the Debtor for entry of an interim order (this “Interim Order”) (i) prohibiting Utility Providers from altering, refusing or discontinuing service; (ii) approving the Debtor’s Proposed Adequate Assurance of payment for postpetition services; and (iii) establishing procedures for resolving requests for additional adequate assurance of payment; the Court having reviewed the Motion and the First Day Declaration; and the Court having jurisdiction over this matter pursuant to 28 U.S.C. 157 and §§ 1334(b); and the Court having found that this matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and the Court 1 The last four digits of the Debtor’s federal taxpayer identification are 2146. The address of the Debtor’s headquarters is 95 Wyman Road, Keene, New Hampshire 03431. 2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Motion.

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having found that venue of this proceeding and the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court having determined that the relief requested in the Motion is in the best interests of the Debtor, the estate, creditors, and other parties in interest; and it appearing that proper and adequate notice of the Motion has been given and that no other or further notice is necessary; and upon the record herein; and after due deliberation thereon; and good and sufficient cause appearing therefore, it is hereby ORDERED, ADJUDGED, AND DECREED THAT: 1. The Motion is GRANTED on an interim basis as set forth herein. 2. The Debtor is authorized to pay on a timely basis, in accordance with prepetition practices, all undisputed invoices for Utility Services rendered by the Utility Providers to the Debtor after the Petition Date. 3. The Debtor shall provide an adequate assurance deposit for all Utility Providers by depositing $30,000.00, which is equal to the estimated cost for two weeks of Utility Services (the “Adequate Assurance Deposit”). The Adequate Assurance Deposit will be deposited into a newly created, segregated account (the “Adequate Assurance Deposit Account”). 4. The Proposed Adequate Assurance comprises the Adequate Assurance Deposit and the Debtor’s ability to pay for future utility services in the ordinary course of business and constitutes sufficient adequate assurance of future payment to the Utility Providers to satisfy the requirements of Bankruptcy Code section 366. 5. Pending entry of the Final Order, the Utility Providers are prohibited from (a) altering, refusing, or discontinuing Utility Services to, or discriminating against, the Debtor on the basis of the commencement of the Chapter 11 Case or on account of any unpaid prepetition charges; (b) drawing upon any existing security deposit, surety bond, or other form of security to

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secure future payment for utility services; or (c) requiring additional adequate assurance of payment other than the Proposed Adequate Assurance, as a condition of the Debtor continuing to receive Utility Services. 6. The following Adequate Assurance Procedures are approved: a. Within two (2) business days of the date the Interim Order is docketed, the Debtor will mail a copy of the Interim Order to the Utility Providers on the Utility Providers List; b. If a Utility Provider is not satisfied with the Proposed Adequate Assurance and seeks additional assurance of payment in the form of a deposit, letter of credit, prepayment, or otherwise, it must serve an Additional Assurance Request upon: (i) proposed counsel to the Debtor (a) Polsinelli PC, 600 Third Avenue, 42nd Floor, New York, New York 10016, Attn: Jeremy R. Johnson (jeremy.johnson@polsinelli.com) and Attn: Stephen J. Astringer (sastringer@polsinelli.com); and (b) Hinckley, Allen & Snyder LLP, 650 Elm Street, Manchester, New Hampshire 03101, Attn: Daniel M. Deschenes (ddeschenes@hinckleyallen.com) and 28 State Street, Boston, Massachusetts 02109, Attn: Jennifer V. Doran (jdoran@hinckleyallen.com); (ii) counsel to UMB Bank, as indenture trustee (the “Bond Trustee”), Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., One Financial Center, Boston, Massachusetts 02111, Attn: Daniel S. Bleck (dsbleck@mintz.com); (iii) the Office of the United States for the District of New Hampshire; and (iv) counsel to any official committee appointed in the Chapter 11 Case (together, the “Notice Parties”); c. Each Additional Assurance Request must (i) be made in writing; (ii) set forth all location(s) for which utility services are provided and the relevant account number(s); (iii) include a summary of the Debtor’s payment history relevant to the affected account(s); (iv) describe any deposits or other security currently held by the requesting Utility Provider; and (v) identify and explain the basis of the Utility Provider’s proposed adequate assurance requirement under Bankruptcy Code section 366(c)(2); d. Upon the Notice Parties’ receipt of an Additional Assurance Request at the addresses set forth in subparagraph (b) above, the Debtor shall promptly negotiate with such Utility Provider to resolve such Utility Provider’s Additional Assurance Request; e. The Debtor may, in its discretion and in consultation with the Bond Trustee, resolve an Additional Assurance Request by mutual

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agreement with the requesting Utility Provider without further notice to the Court or any other party in interest, and may, in connection with any such agreement, provide a Utility Provider with additional adequate assurance of future payment, including, but not limited to, cash deposits, prepayments, letters of credit, and/or other forms of security, without further order of the Court to the extent that the Debtor believes such additional assurance is reasonable in the exercise of its business judgment and the Debtor may, by mutual agreement with the objecting Utility Provider and without further order of the Court, reduce the Adequate Assurance Deposit by an amount not exceeding the requesting Utility Provider’s estimated two-week utility expense; f. If the Debtor determines that a timely received Additional Assurance Request is not reasonable and is unable to reach an alternative resolution with the applicable Utility Provider within 30 days of the date the Additional Assurance Request was made, or such later date to which the Debtor and the applicable Utility Provider agree, the Debtor shall, upon reasonable notice, calendar the matter (the “Adequate Assurance Dispute”) for the next regularly scheduled omnibus hearing to determine the adequacy of assurance of payment pursuant to Bankruptcy Code section 366(c)(3); g. Pending resolution of any such Adequate Assurance Dispute, any such Utility Provider shall be prohibited from altering, refusing, or discontinuing service to the Debtor on account of unpaid charges for prepetition services, the filing of the Chapter 11 Case, or any objection to the adequacy of the Proposed Adequate Assurance; and h. Upon the termination of Utility Services, the Debtor may, in its discretion and upon fourteen (14) days’ notice to the parties in interest, Notice Parties, and all affected Utility Providers, reduce the Adequate Assurance Deposit by an amount not exceeding, for each of the Utility Services being discontinued, the lesser of (a) the estimated two-week utility expense for such Utility Services, and (b) the amount of the Adequate Assurance Deposit then attributable to the applicable Utility Provider, provided that there are no outstanding disputes related to postposition amounts due. 7. The Debtor may supplement the Utility Providers List without further order of the Court with Additional Utility Providers if such Additional Utility Providers were inadvertently omitted from the Utility Providers List, and the Debtor will file as soon as practicable with the Court a supplement to Exhibit 1 attached hereto that adds the name of any Additional Utility

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Provider to the Utility Providers List. The Debtor will then serve by email or by facsimile transmission (or, where the Debtor does not have the email address or fax number of an Additional Utility Provider, by First Class Mail) a copy of the Motion and this Interim Order on any Additional Utility Provider. The Debtor will also supplement the Adequate Assurance Deposit in an amount equal to 50% of the Debtor’s average monthly utility consumption over the course of 12 months for an added Utility Provider. 8. The Debtor may amend the Utility Service List to delete a Utility Provider, or may seek to terminate a Utility Provider, upon fourteen (14) days’ notice to the parties in interest and all affected Utility Providers and only if the Debtor has not received any objection from such Utility Provide or any other parties in interest. If an objection is received, the Debtor shall request a hearing before this Court at the next omnibus hearing date, or such other date that the Debtor and the Utility Provider may agree. The Debtor shall not deduct from the Utility Deposit the amount set aside for any Utility Company that the Debtor seeks to terminate or delete from Exhibit 1 unless and until the two week notice period has passed and the Debtor has not received any objection to termination or deletion from such Utility Company or any parties in interest, or until any such objection has been resolved consensually or by order of the Court. 9. No money may be withdrawn from the Adequate Assurance Deposit Account except (a) in compliance with the Adequate Assurance Procedures, (b) by mutual agreement of the Debtor and the applicable Utility Provider, or (c) by further order of the Court. If the Debtor fails to pay for any legitimate postpetition Utility Services when due, a Utility Provider may access only that portion of the Adequate Assurance Deposit attributable to it in the Adequate Assurance Deposit Account.

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10. The Debtor shall administer the Adequate Assurance Deposit Account in accordance with the terms of this Interim Order, pending entry of a Final Order. 11. Nothing contained herein constitutes a finding that any entity is or is not a Utility Provider hereunder or under Bankruptcy Code section 366, whether or not such entity is listed on the Utility Providers List. 12. Within two (2) business days of the date of this Interim Order, the Debtor shall serve a copy of this Interim Order and the Motion on each Utility Provider identified on the Utility Providers List. Within two (2) business days of filing a supplement to the Utility Providers List, as applicable, the Debtor shall serve a copy of this Interim Order and the Motion on any applicable Additional Utility Provider. 13. Nothing in the Motion or this Interim Order, or the Debtor’s payment of any claims pursuant to this Interim Order, shall be deemed or construed as: (a) an admission as to the validity of any claim or lien against the Debtor or the estate; (b) a waiver of the Debtor’s rights to dispute any claim or lien; (c) a waiver of a Utility Provider’s rights with regard to assertion of any claim or interest; (d) an approval or assumption of any agreement, contract, or lease pursuant to Bankruptcy Code section 365; (e) an admission of the priority status of any claim, whether under Bankruptcy Code section 503(b)(9) or otherwise; or (f) a modification of the Debtor’s rights to seek relief under any section of the Bankruptcy Code on account of any amounts owed or paid to any Utility Provider. 14. Nothing in this Order authorizes the Debtor to pay prepetition claims without further order of the Court. 15. The requirements set forth in Bankruptcy Rule 6003(b) are satisfied.

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16. Notice of the Motion as provided therein shall be deemed good and sufficient and the requirements of Bankruptcy Rule 6004(a) and the Local Rules are satisfied by such notice. 17. Notwithstanding any Bankruptcy Rule (including, but not limited to, Bankruptcy Rule 6004(h)) or Local Bankruptcy Rule that might otherwise delay the effectiveness of this Interim Order, the terms and conditions of this Interim Order shall be immediately effective and enforceable upon its entry. 18. The final hearing (the “Final Hearing”) to consider the entry of a final order granting the relief requested in the Motion shall be held on _______, 2021, at __:__ _.m. (Eastern Time). 19. Any objection to the entry of a final order granting the relief requested in the Motion shall be filed with the Court and served on, no later than __________, 2021, at 4:00 p.m. (Eastern Time): (i) proposed counsel to the Debtor (a) Polsinelli PC, 600 Third Avenue, 42nd Floor, New York, New York 10016, Attn: Jeremy R. Johnson (jeremy.johnson@polsinelli.com) and Attn: Stephen J. Astringer (sastringer@polsinelli.com); and (b) Hinckley, Allen & Snyder LLP, 650 Elm Street, Manchester, New Hampshire 03101, Attn: Daniel M. Deschenes (ddeschenes@hinckleyallen.com) and 28 State Street, Boston, Massachusetts 02109, Attn: Jennifer V. Doran (jdoran@hinckleyallen.com); (ii) counsel to UMB Bank, as indenture trustee, Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., One Financial Center, Boston, Massachusetts 02111, Attn: Daniel S. Bleck (dsbleck@mintz.com); (iii) the Office of the United States for the District of New Hampshire; and (iv) counsel to any official committee appointed in the Chapter 11 Case

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20. All payments made pursuant to this Interim Order shall be subject to any interim or final order entered by the Court governing the Debtor’s right to the use the Bond Trustee’s cash collateral, including the budget attached thereto. 21. The Debtor is authorized to take all actions it deems necessary to effectuate the relief granted pursuant to this Interim Order in accordance with the Motion. 22. Notwithstanding any Bankruptcy Rule that might otherwise delay the effectiveness of this Interim Order, the terms and conditions of this Interim Order shall be immediately effective and enforceable upon its entry. 23. This Court shall retain jurisdiction over any and all matters arising from the interpretation, implementation, or enforcement of this Interim Order. Dated: _________________, 2021 Concord, New Hampshire UNITED STATES BANKRUPTCY JUDGE

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Exhibit 1 to the Interim Order Utility Provider Utility Provider Address Utility Type Average Monthly Total Cost in Name TTM 7/31/21 TTM 7/31/21 PSNH - Eversource PO Box 56003 Electricity $11,909.16 $142,909.94 Boston, MA 02205-6003 Direct Energy PO Box 70220 Electricity $10,082.50 $120,989.64 Philadelphia, PA 19176- 0220 U.S. Cellular Dept. 0205 Mobile Phone $335.47 $4,025.64 Palatine, IL 60055-0205 Ascentium Capital PO Box 301593 Cable TV $4,136.50 $49,637.94 Dallas, TX 75303-1593 Suburban Propane PO Box 160 Gas $16,234.64 $194,815.66 Whippany, NJ 07981-0160 First Light Fiber PO Box 1301 Telephone $514.87 $6,178.45 Williston, VT 05495-1301 City of Keene PO Box 544 Water and Sewage $4,286.32 $51,438.89 Keene, NH 03431-0544 Single Digits, Inc. PO Box 93363 Telephone, Internet, $13,026.15 $156,313.83 Las Vegas, NV 89193-3363 IT Support Consolidated PO Box 11560 Telephone $51.17 $614.05 Communications, Inc. Portland, ME 04104 Waste Management PO Box 13648 Trash $3,549.69 $42,596.33 Corporate Services, Philadelphia, PA 19101- Inc. 3646

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Exhibit B Proposed Final Order

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF NEW HAMPSHIRE In re: ) Chapter 11 ) Prospect-Woodward Home, ) Case No. 21-______ (____) ) Debtor. 1 ) Re: Docket No. _____ ) FINAL ORDER (I) PROHIBITING UTILITY PROVIDERS FROM ALTERING, REFUSING, OR DISCONTINUING SERVICE, (II) APPROVING THE DEBTOR’S PROPOSED ADEQUATE ASSURANCE OF PAYMENT FOR POSTPETITION SERVICES, AND (III) ESTABLISHING PROCEDURES FOR RESOLVING REQUESTS FOR ADDITIONAL ADEQUATE ASSURANCE OF PAYMENT FOR POSTPETITION SERVICES, AND (III) ESTABLISHING PROCEDURES FOR RESOLVING REQUESTS FOR ADDITIONAL ADEQUATE ASSURANCE OF PAYMENT Upon the Emergency Ex Parte Motion of Debtor for Entry of Interim and Final Orders (I) Prohibiting Utility Providers from Altering, Refusing, or Discontinuing Service, (II) Approving the Debtor’s Proposed Adequate Assurance of Payment for Postpetition Services, and (III) Establishing Procedures for Resolving Requests for Additional Adequate Assurance of Payment for Postpetition Services, and (III) Establishing Procedures for Resolving Requests for Additional Adequate Assurance of Payment (the “Motion”)2 of the Debtor for entry of an final order (this “Final Order”) (i) prohibiting Utility Providers from altering, refusing or discontinuing service; (ii) approving the Debtor’s Proposed Adequate Assurance of payment for postpetition services; and (iii) establishing procedures for resolving requests for additional adequate assurance of payment; the Court having reviewed the Motion, the First Day Declaration, and the Interim Order; and the Court having jurisdiction over this matter pursuant to 28 U.S.C. 157 and §§ 1334(b); and the Court having found that this matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and 1 The last four digits of the Debtor’s federal taxpayer identification are 2146. The address of the Debtor’s headquarters is 95 Wyman Road, Keene, New Hampshire 03431. 2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Motion.

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the Court having found that venue of this proceeding and the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court having determined that the relief requested in the Motion is in the best interests of the Debtor, the estate, creditors, and other parties in interest; and it appearing that proper and adequate notice of the Motion has been given and that no other or further notice is necessary; and upon the record herein; and after due deliberation thereon; and good and sufficient cause appearing therefore, it is hereby ORDERED, ADJUDGED, AND DECREED THAT: 1. The Motion is GRANTED on a final basis as set forth herein. 2. The Debtor is authorized to pay on a timely basis, in accordance with prepetition practices, all undisputed invoices for Utility Services rendered by the Utility Providers to the Debtor after the Petition Date. 3. To the extent not otherwise already done, the Debtor shall provide an adequate assurance deposit for all Utility Providers by depositing $30,000.00, which is equal to the estimated cost for two weeks of Utility Services (the “Adequate Assurance Deposit”). The Adequate Assurance Deposit will be deposited into a newly created, segregated account (the “Adequate Assurance Deposit Account”). 4. The Proposed Adequate Assurance comprises the Adequate Assurance Deposit and the Debtor’s ability to pay for future utility services in the ordinary course of business and constitutes sufficient adequate assurance of future payment to the Utility Providers to satisfy the requirements of Bankruptcy Code section 366. 5. The Utility Providers are prohibited from: (a) altering, refusing, or discontinuing Utility Services to, or discriminating against, the Debtor on the basis of the commencement of the Chapter 11 Case or on account of any unpaid prepetition charges; (b) drawing upon any existing

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security deposit, surety bond, or other form of security to secure future payment for utility services; or (c) requiring additional adequate assurance of payment other than the Proposed Adequate Assurance, as a condition of the Debtor continuing to receive Utility Services. 6. The following Adequate Assurance Procedures are approved: a. If a Utility Provider is not satisfied with the Proposed Adequate Assurance and seeks additional assurance of payment in the form of a deposit, letter of credit, prepayment, or otherwise, it must serve an Additional Assurance Request upon: (i) proposed counsel to the Debtor (a) Polsinelli PC, 600 Third Avenue, 42nd Floor, New York, New York 10016, Attn: Jeremy R. Johnson (jeremy.johnson@polsinelli.com) and Attn: Stephen J. Astringer (sastringer@polsinelli.com); and (b) Hinckley, Allen & Snyder LLP, 650 Elm Street, Manchester, New Hampshire 03101, Attn: Daniel M. Deschenes (ddeschenes@hinckleyallen.com) and 28 State Street, Boston, Massachusetts 02109, Attn: Jennifer V. Doran (jdoran@hinckleyallen.com); (ii) counsel to UMB Bank, as indenture trustee (the “Bond Trustee”), Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., One Financial Center, Boston, Massachusetts 02111, Attn: Daniel S. Bleck (dsbleck@mintz.com); (iii) the Office of the United States for the District of New Hampshire; and (iv) counsel to any official committee appointed in the Chapter 11 Case (together, the “Notice Parties”); b. Each Additional Assurance Request must (i) be made in writing; (ii) set forth all location(s) for which utility services are provided and the relevant account number(s); (iii) include a summary of the Debtor’s payment history relevant to the affected account(s); (iv) describe any deposits or other security currently held by the requesting Utility Provider; and (v) identify and explain the basis of the Utility Provider’s proposed adequate assurance requirement under Bankruptcy Code section 366(c)(2); c. Upon the Notice Parties’ receipt of an Additional Assurance Request at the addresses set forth in subparagraph (b) above, the Debtor shall promptly negotiate with such Utility Provider to resolve such Utility Provider’s Additional Assurance Request; d. The Debtor may, in its discretion and in consultation with the Bond Trustee, resolve an Additional Assurance Request by mutual agreement with the requesting Utility Provider without further notice to the Court or any other party in interest, and may, in connection with any such agreement, provide a Utility Provider with additional adequate assurance of future payment, including, but not

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limited to, cash deposits, prepayments, letters of credit, and/or other forms of security, without further order of the Court to the extent that the Debtor believes such additional assurance is reasonable in the exercise of its business judgment and the Debtor may, by mutual agreement with the objecting Utility Provider and without further order of the Court, reduce the Adequate Assurance Deposit by an amount not exceeding the requesting Utility Provider’s estimated two-week utility expense; e. If the Debtor determines that a timely received Additional Assurance Request is not reasonable and is unable to reach an alternative resolution with the applicable Utility Provider within 30 days of the date the Additional Assurance Request was made, or such later date to which the Debtor and the applicable Utility Provider agree, the Debtor shall, upon reasonable notice, calendar the matter (the “Adequate Assurance Dispute”) for the next regularly scheduled omnibus hearing to determine the adequacy of assurance of payment pursuant to Bankruptcy Code section 366(c)(3); f. Pending resolution of any such Adequate Assurance Dispute, any such Utility Provider shall be prohibited from altering, refusing, or discontinuing service to the Debtor on account of unpaid charges for prepetition services, the filing of the Chapter 11 Case, or any objection to the adequacy of the Proposed Adequate Assurance; g. Upon the termination of Utility Services, the Debtor may, in its discretion and upon fourteen (14) days’ notice to the parties in interest, Notice Parties, and all affected Utility Providers, reduce the Adequate Assurance Deposit by an amount not exceeding, for each of the Utility Services being discontinued, the lesser of (a) the estimated two-week utility expense for such Utility Services, and (b) the amount of the Adequate Assurance Deposit then attributable to the applicable Utility Provider, provided that there are no outstanding disputes related to postposition amounts due. 7. The Debtor may supplement the Utility Providers List without further order of the Court with Additional Utility Providers if such Additional Utility Providers were inadvertently omitted from the Utility Providers List, and the Debtor will file as soon as practicable with the Court a supplement to Exhibit 1 annexed to the Interim Order that adds the name of any Additional Utility Provider to the Utility Providers List. The Debtor will then serve by email or by facsimile transmission (or, where the Debtor does not have the email address or fax number of an Additional

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Utility Provider, by First Class Mail) a copy of the Motion and this Interim Order on any Additional Utility Provider. The Debtor will also supplement the Adequate Assurance Deposit in an amount equal to 50% of the Debtor’s average monthly utility consumption over the course of 12 months for an added Utility Provider. 8. The Debtor may amend the Utility Service List to delete a Utility Provider, or may seek to terminate a Utility Provider, upon fourteen (14) days’ notice to the parties in interest and all affected Utility Providers and only if the Debtor has not received any objection from such Utility Provide or any other parties in interest. If an objection is received, the Debtor shall request a hearing before this Court at the next omnibus hearing date, or such other date that the Debtor and the Utility Provider may agree. The Debtor shall not deduct from the Utility Deposit the amount set aside for any Utility Company that the Debtor seeks to terminate or delete from Exhibit 1 annexed to the Interim Order unless and until the two week notice period has passed and the Debtor has not received any objection to termination or deletion from such Utility Company or any parties in interest, or until any such objection has been resolved consensually or by order of the Court. 9. No money may be withdrawn from the Adequate Assurance Deposit Account except (a) in compliance with the Adequate Assurance Procedures, (b) by mutual agreement of the Debtor and the applicable Utility Provider, or (c) by further order of the Court. If the Debtor fails to pay for any legitimate postpetition Utility Services when due, a Utility Provider may access only that portion of the Adequate Assurance Deposit attributable to it in the Adequate Assurance Deposit Account. 10. The Debtor shall administer the Adequate Assurance Deposit Account in accordance with the terms of this Final Order.

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11. Nothing contained herein constitutes a finding that any entity is or is not a Utility Provider hereunder or under Bankruptcy Code section 366, whether or not such entity is listed on the Utility Providers List. 12. Within two (2) business days of the date of this Final Order, the Debtor shall serve a copy of this Final Order on each Utility Provider identified on the Utility Providers List. Within two (2) business days of filing a supplement to the Utility Providers List, as applicable, the Debtor shall serve a copy of this Final Order and the Motion on any Additional Utility Provider. 13. Nothing in the Motion or this Final Order, or the Debtor’s payment of any claims pursuant to this Final Order, shall be deemed or construed as: (a) an admission as to the validity of any claim or lien against the Debtor or the estate; (b) a waiver of the Debtor’s rights to dispute any claim or lien; (c) a waiver of a Utility Provider’s rights with regard to assertion of any claim or interest; (d) an approval or assumption of any agreement, contract, or lease pursuant to Bankruptcy Code section 365; (e) an admission of the priority status of any claim, whether under Bankruptcy Code section 503(b)(9) or otherwise; or (f) a modification of the Debtor’s rights to seek relief under any section of the Bankruptcy Code on account of any amounts owed or paid to any Utility Provider. 14. Nothing in this Order authorizes the Debtor to pay prepetition claims without further order of the Court. 15. All payments made pursuant to this Final Order shall be subject to any interim or final order entered by the Court governing the Debtor’s right to the use the Bond Trustee’s cash collateral, including the budget attached thereto. 16. The requirements set forth in Bankruptcy Rule 6003(b) are satisfied.

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17. Notice of the Motion as provided therein shall be deemed good and sufficient and the requirements of Bankruptcy Rule 6004(a) and the Local Rules are satisfied by such notice. 18. Notwithstanding any Bankruptcy Rule (including, but not limited to, Bankruptcy Rule 6004(h)) or Local Bankruptcy Rule that might otherwise delay the effectiveness of this Final Order, the terms and conditions of this Final Order shall be immediately effective and enforceable upon its entry. 19. The Debtor is authorized to take all actions it deems necessary to effectuate the relief granted pursuant to this Order in accordance with the Motion. 20. Notwithstanding any Bankruptcy Rule that might otherwise delay the effectiveness of this Final Order, the terms and conditions of this Final Order shall be immediately effective and enforceable upon its entry. 21. This Court shall retain jurisdiction over any and all matters arising from the interpretation, implementation, or enforcement of this Final Order. Dated: _________________, 2021 Concord, New Hampshire UNITED STATES BANKRUPTCY JUDGE

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