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which Villa will fully release CdcW and new C6W and all affiliated <br />companies, their directors, officers, employees, agents, <br />successors and assigns from any and all claims now or in the <br />future, and waiving the right to exercise any seniority rights or <br />return to work. <br />A copy of the Release is attached hereto as Exhibit 1 <br />and is incorporated herein by reference. In order to avoid the <br />time, expense and uncertainties of litigation and to settle the <br />disputes between them, The C&W and Villa entered into the <br />Release. The C&W, using its business judgment, having analyzed <br />potential defenses which it might assert against Villa, and <br />having considered the liklihood of success if the District Court <br />case were to be tried, has determined that approval of the <br />Release is in the best interest of the estate. <br />PLEASE TAKE FURTHER NOTICE that, pursuant to Rule <br />523(b) of the Rules of Practice of the United States Bankruptcy <br />Court for the District of Utah, objections to the Notion must be <br />submitted in writing, filed with the Bankruptcy Court, and served <br />upon the undersigned counsel on or before Monday, Janary 3, 1994. <br />Absent timely filing and service of objections, the hearing may <br />be stricken and the relief sought in the notion may be granted by <br />the Court without further notice or hearing. Additionally, upon <br />the resolution of any timely filed and served objections, the <br />-3- <br />