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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:
Cross-collateralization, defined as securing prepetition debt by postpetition assets in which the secured creditor would not otherwise have a security interest.
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.
Provisions waiving the estate's rights to seek surcharge under § 506(c).
Provisions immediately granting a prepetition secured creditor liens against the debtor's causes of action arising under §§ 544, 545, 547, 548 and 549.
Provisions that deem prepetition secured debt to be postpetition debt, or that use postpetition loans from a prepetition secured creditor to pay all or part of that creditor's prepetition debt.
Provisions that provide disparate treatment for the committee's professionals from
