Similarly, each Member Club incurs considerable scheduling and travel costs when visiting the Debtor's home arena. If the Debtor fails to put a team on the ice, the visiting Member Club, and the UHL, will be negatively and irreversibly harmed. 10.Similarly, absent immediate consideration of the Motion, the overall competitive balance of the UHL is subject to irreversible damage. The Debtor's use of replacement players threatens the overall integrity of the competitive athletic process . 11.The integrity and reputation of the UHL, and each of its other Member Clubs, is also threatened with irrevocable harm.
Consumers have many options when it comes to spending their recreational dollars.
The UHL and its Member Clubs depend upon providing the admission-paying public with the best professional athletic product available. If the integrity of the competition is questioned, as it is with the Debtor's use of replacement players, the direct result is serious financial impairment and damage to the UHL's reputation. 12.The personal safety and welfare of the Debtor's players are also threatened absent the Court's prompt interaction. The Debtor's schedules list substantial obligations for unpaid health insurance, workers' compensation and disability insurance. Upon information and belief, the Debtor has not sought approval for the use of cash collateral, or to arrange third-party financing.