Extract to table

Operating Cash Requirements Beyond the administrative costs of the Chapter 11 case itself, the DIP budget must account for TAI's ongoing operating cash requirements during the pendency of the case

Section 363(e) of the Bankruptcy Code provides that upon the request of an entity with an interest in property used, sold, or leased by the debtor (or proposed to be used, sold, or leased by the debtor), the court shall prohibit or condition such use, sale, or lease as is necessary to provide adequate protection of such interest

Accordingly, TAI must demonstrate that adequate protection exists for both classes of prepetition secured creditors

The twelve-month case timeline contemplated by the DIP facility means that the collateral must hold its value through mid-2024

These arguments, while not without force, must be weighed against the constraints imposed by the Intercreditor Agreement and the broader interests of the estate and its creditor constituencies