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Co-Counsel For F&G Mechanical Corporation Meadowlands Fire Protection
Co-Counsel For F&G Mechanical Corporation Meadowlands Fire Protection
Co-Counsel For F&G Mechanical Corporation Meadowlands Fire Protection
140 Broadway New York, New York 10005 Tel: (212) 248-3140 Fax: (212) 248-3141
Co-counsel for F&G Mechanical Corporation and Meadowlands Fire Protection
In re: Chapter II LEHR CONSTRUCTION CORP., Case No. Il -10723 (SHL) Debtor.
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JOINDER TO LIMITED OBJECTION AND RESERVATION OF RIGHTS OFF &G MECHANCIAL CORPORATION AND MEADOWLANDS FIRE PROTECTION TO DEBTOR'S EMERGENCY MOTION FOR INTERIM AND FINAL (I) APPROVAL OF POSTPETITION FINANCING, (II) AUTHORITY TO USE CASE COLLATERAL, (III) GRANTING OF CERTAIN LIENS, (IV) GRANTING ADEQUATE PROTECTION, AND M MODIFYING THE AUTOMATIC STAY F&G Mechanical Corporation ("F&G") and Meadowlands Fire Protection ("MFP"), by and through their undersigned counsel, hereby submit this joinder to the Limited Objection (the "Limited Objection") to the motion of Lehr Construction Corporation (the "Debtor") for entry of interim and final (I) approval of post-petition financing, (II) authority to use cash collateral, (III) granting of certain liens, (IV) granting adequate protection, and (V) modifying the automatic stay (the "DIP Financing Motion"). In support ofthe Limited Objection, F&G and MFP respectfully state as follows:
FPO 1/ 6482056.1
F&G and MFP hereby adopt the position and arguments set forth in their
previously filed Limited Objection to the DIP Financing Motion and for the reasons set forth therein, extend the same limited objection to the Debtor's request for authorization to grant adequate protection to its prepetition lender for use of Cash Collateral.
WHEREFORE, F&G and MFP respectfully request the entry of an order granting
the limited objection to the extent set forth herein, and granting such other and further relief as the Court deems just and proper. Dated: March 17, 2011 Respectfully submitted,
140 Broadway New York, New York 10005 Tel: (212) 248-3140 Fax: (212) 248-3141
By:
FPO 1/6482056.1
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