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1. On November 7, 1990, (the "Petition Date"), Debtor <br />commenced its reorganization case by filing a voluntary petition <br />for relief under chapter 11 of the Bankruptcy Code. <br />2. Debtor is continuing in possession of its property <br />and is operating and managing its business, as a debtor in <br />possession, pursuant to sections 1107 and 1108 of the Bankruptcy <br />Code. <br />3. The Court has jurisdiction over this matter <br />pursuant to 28 U.S.C. §§ 157 and 1334. This is a core proceeding <br />pursuant to 28 U.S.C. § 157(b)(2)(A). <br />REQUEST FOR PAYMENT AUTHORIZATION <br />4. The Debtor has had from 1987 to the presen1t time <br />an Employee Stock Option Plan (the "Plan") which is governed and <br />administered by the document with amendments, pertinent portions <br />attached hereto as Exhibit A (the "Plan Administration <br />Document"). <br />5. The Plan was established and is maintained <br />pursuant to a settlement agreement dated October 15, 1986, <br />between the Debtor and the United Steelworkers of America. See <br />copy of the settlement agreement, attached hereto as Exhibit H. <br />The settlement agreement, by its terms, became part of and was <br />incorporated into the collective bargaining agreement between the <br />Debtor and the Steelworkers dated October 15, 1986. The <br />October 15, 1986 collective bargaining agreement was <br />incorporated, with some modifications not related to the P.Lan, <br />into the current collective bargaining agreement between tlae <br />2 <br />