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<br />Debtor and the Steelworkers dated October 15, 1989. See <br />Settlement Agreement, dated October 15 1989, Exhibit C. <br />6. The Plan Administration Document, at Sections 8 <br />and 16(c)(6), allows the Plan to hire legal counsel at the <br />expense of the Debtor. <br />7. Since its inception, the Plan has retained the law <br />firm of Keck, Mahin and Cate, and especially its partner Jack <br />Curtis, as counsel to render legal advice to the Plan as needed. <br />8. At the present time, the Plan wishes to have the <br />law firm of Keck, Mahin and Cate perform certain legal service on <br />its behalf. Those services include (1) preserving the continuing <br />qualification of the Plan under the IRS and under ERISA and (2) <br />advising the Plan fiduciaries as to their obligations under ERISA <br />with respect to the Plan. The Debtor is obligated to pay for such <br />services under the Plan Administration Document provisions cited <br />above. <br />9. Bankruptcy Rule 2016 states that "an entity <br />seeking interim or final compensation for services, or <br />reimbursement of necessary expenses, from the estate shall file <br />with the court an application " Furthermore, Bankruptcy <br />Rule 2017(b) authorizes the Court to monitor any payment made by <br />a debtor to an attorney after the commencement of a case. <br />Accordingly, CF&I Steel believes that any payment that it makes <br />to an attorney is subject to court scrutiny and approval. <br />10. By this Application, the Debtor seeks Court <br />authorization to make payment to Keck for legal services rendered <br />to the Plan and for expenses incurred in connection therewith. <br />3 <br />