The US Bankruptcy Court gave an order granting the conversion of Chapter 11 reorganization case of Diversified Resources Inc. to liquidation under Chapter 7 on September 5, 2019. The debtor is unable to obtain insurance for its lands as the property situated at tribal lands and the sovereign immunity issues on those lands. Absence of insurance can lead to cease operations of the debtor. In addition to it, the debtor is also unable to obtain DIP loan facility in order to provide capital for ongoing operations. Hence, case conversion is best in interests for creditors and estate too.