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12. The Reorganized Debtors propose that the bond be <br />obtained in the amount of Twenty-One Million Five Hundred <br />Thousand and no/100 Dollars ($21,500,000.00) in behalf of Scott <br />C. King, Responsible Director, and David Houghton, Responsible <br />Officer, as principals, from Fireman's Insurance Company of <br />Newark, New Jersey, as surety, and that the bond be renewed each <br />year in an amount rounded to the nearest Five Hundred Thousand <br />Dollars ($500,000.00) that exceeds that amount of aggregate cash <br />in the custody, control and supervision of the Responsible <br />Director and Responsible Officer as of the renewal date. <br />Based on the foregoing, the Reorganized Debtors respectfully <br />request that the Court enter an Order Granting Motion Dated <br />November 1, 1993 for Order Authorizing Reorganized Debtors to <br />Obtain Bond for Responsible Director and Responsible Officer and <br />for such further relief as the Court deems proper. <br />DATED this 1 day of November, 1993. <br />RAY, QUZNNEY & NEBEKER <br />~~~ ~~ ~~ <br />WESTON L. HARRIS <br />Attorneys for Reorganized Debtors <br />rsm~m <br />-5- <br />