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<br /> <br />Motion To Withdraw Reorganized Debtors' Motion for Entry of Order <br />in Aid of Consummation of Debtors' and Railroad Trustee's First <br />Amended and Restated Plan of Reorganization Dated December ]_, <br />1993, Brief in Support of Motion To Withdraw and Application for <br />Transmittal Order and Certification Pursuant to Local Rule 405 <br />("Withdrawal Papers"}. <br />PLEASE TAKE FURTHER NOTICE that The Secretary has also filed <br />a Brief in Opposition to Reorganized Debtors' Motion for Entry of <br />Order in Aid of Consummation of Debtors' and Railroad Trustee's <br />First Amended and Restated Plan of Reorganization Dated December <br />1, 1993, Declaration of Dr. Dan M. McGill and Motion for Leave to <br />File Hrief Exceeding Page Limitations ("Opposition Papers"). <br />All Withdrawal Papers and all Opposition Papers have been <br />served upon the Pension Benefit Guaranty Corporation, Mellon <br />Bank, N.A., Mellon Equity Associates and Reorganized Debtors' <br />counsel, LeBeouf, Lamb, Leiby & MacRae (Salt Lake City and <br />Washington, D.C.). Other parties seeking a copy of any or a:Ll of <br />the Withdrawal Papers or Opposition Papers may obtain copies by <br />making a written request to the Secretary's counsel at the <br />address set forth below. <br />The Secretary contends that withdrawal of Reorganized <br />Debtors' motion is required pursuant to 28 U.S.C. § 157 (d) <br />because its determination necessarily requires consideration of <br />the Employee Retirement Income Security Act of 1974 ("ERISA"), 28 <br />U.S.C. § 1001 et seo• The Secretary, in his Opposition Papers, <br />opposes Reorganized Debtors' Motion on several grounds. First, <br />2 <br />