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Full title: Motion to File Document under Seal, filed by Key-Way, LLC (RE: related document(s)[1889] Motion to Compel filed by Creditor Key-Way, LLC) (Attachments: # (1) Proposed Order proposed order) (Hostettler, R.)

Document posted on Dec 16, 2021 in the bankruptcy, 2 pages and 0 tables.

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CHAPTER 11 DEBTORS MOTION FOR LEAVE TO FILE SEALED DOCUMENT and TO RESTRICT PUBLIC ACCESS *** *** *** Comes now Key-Way, LLC (“Key-Way”), a creditor and critical vendor in these proceedings, by and through counsel, and consistent with the instructions of the Court at the December 16, 2021 hearing on Key-Way’s Motion to Compel American Resources Corporation to pay post-petition trade payables [ECF Doc. 1889], and in accordance with Section XXII of the Court’s Administrative Procedures Manual, herewith moves this Court leave to file as a sealed document the Critical Vendor Agreement entered into between the debtors in possession and Key-Way, LLC and that access to such document be restricted.The Critical Vendor Agreement contains a paragraph that requires Key Way to maintain the confidentiality of the subject agreement.At the hearing in this matter on the subject Motion, the Court directed counsel for Key-Way to file the Critical Vendor Agreement as a sealed document in the record.Notice is hereby given that pursuant to local rule 9013-1(c)(xii) the foregoing Motion may be ruled upon by the Court without a hearing.The undersigned does hereby certify that a true copy of the foregoing Motion was served this the __17th_ day of December 2021 electronically in accordance with the method established under this Court’s CM/ECF administrative procedures upon all parties in the electronic filing system in this case including the United States Trustee and debtors’ counsel and counsel for the unsecured creditors committee.

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF KENTUCKY LEXINGTON DIVISION CASE NO. 19-51200 (Jointly Administered) IN RE: CAMBRIAN HOLDING COMPANY, INC., et al. CHAPTER 11 DEBTORS MOTION FOR LEAVE TO FILE SEALED DOCUMENT and TO RESTRICT PUBLIC ACCESS *** *** *** Comes now Key-Way, LLC (“Key-Way”), a creditor and critical vendor in these proceedings, by and through counsel, and consistent with the instructions of the Court at the December 16, 2021 hearing on Key-Way’s Motion to Compel American Resources Corporation to pay post-petition trade payables [ECF Doc. 1889], and in accordance with Section XXII of the Court’s Administrative Procedures Manual, herewith moves this Court leave to file as a sealed document the Critical Vendor Agreement entered into between the debtors in possession and Key-Way, LLC and that access to such document be restricted. The Critical Vendor Agreement contains a paragraph that requires Key Way to maintain the confidentiality of the subject agreement. At the hearing in this matter on the subject Motion, the Court directed counsel for Key-Way to file the Critical Vendor Agreement as a sealed document in the record. Respectfully submitted, HAMM, MILBY & RIDINGS, PLLC 120 NORTH MAIN STREET LONDON, KY 40741 EMAIL: aaron@hmrkylaw.com PHONE: 606-864-4126 FAX: 606-878-8144 Counsel for Key-Way, LLC

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BY:__/s/ R. Aaron Hostettler________________ R. AARON HOSTETTLER NOTICE: Notice is hereby given that pursuant to local rule 9013-1(c)(xii) the foregoing Motion may be ruled upon by the Court without a hearing. __/s/ R. Aaron Hostettler___________________ OF COUNSEL FOR KEY-WAY, LLC CERTIFICATE OF SERVICE: The undersigned does hereby certify that a true copy of the foregoing Motion was served this the __17th_ day of December 2021 electronically in accordance with the method established under this Court’s CM/ECF administrative procedures upon all parties in the electronic filing system in this case including the United States Trustee and debtors’ counsel and counsel for the unsecured creditors committee. __/s/ R. Aaron Hostettler_________________ OF COUNSEL FOR KEY-WAY, LLC

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