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<br />v 1. Proler has filed an administrative priority claim <br />("Claim") in this case in the amount of $283,358.65'. ~1'he Claim is <br />based upon Proler's valid claims for reclamation of goods received <br />by CF&I during the ten days prior to Proler's initial claim, which <br />was delivered on August 9, 1990. Because Proler believes its Claim <br />is valid, and because the treatment proposed by Debtor's Motion for <br />that Claim would deny Proler a reasonable opportunity to enforce <br />its rights in this Case, Proler objects to Debtor's Motion on both <br />procedural and substantive grounds. <br />Procedural Objections <br />2. Proler has timely and properly filed its Claim in this <br />case. No party in interest, including the Debtor, has filed any <br />objection to Proler's claim. Therefore, pursuant to section 502(a) <br />of the United States Bankruptcy Code, Proler's Claim is deemed <br />allowed in full at this time. <br />3. Debtor's Motion improperly seeks to disallow Proler's <br />Claim even though no objection to the Claim has been filed and even <br />though Proler has not been afforded any opportunity to take <br />discovery with respect to the allegations contained in the Debtor's <br />Motion. Proler disputes certain of the critical factual <br />allegations of Debtor's Motion and should be permitted to take <br />discovery with respect to those allegations before any ruling is <br />made on Proler's claim. If Debtor wishes to object to Proler's <br />claim it should do so formally so that Proler may be afforded the <br />'Proler has also filed a general unsecured claim in the amount <br />of $557,307.99. <br />-2- <br />