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Last modified
8/24/2016 7:57:12 PM
Creation date
11/23/2007 8:53:08 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977376
IBM Index Class Name
General Documents
Doc Name
MEMO IN SUPPORT OF MOTION FOR ORDER APPROVING ASSUMPTION OF EXECUTORY CONTRACT WITH COASTAL GAS MARK
Media Type
D
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4 <br />Affidavit, such a disruption could severely harm CF&I Steel's <br />business. <br />C. CFSI Steel Has Met the Requirements of 11 U.S.C. <br />§ 365(b)(1)(A), (B) and (C). <br />In accordance with the requirements set forth in section <br />365(b)(1) of the Bankruptcy Code, CF&I Steel is prepared to (1) <br />cure or provide adequate assurance of prompt cure of all defaults <br />under all the Agreement, (2) pay or provide adequate assurance of <br />payment of any and all actual pecuniary loss suffered by Coastal, <br />and (3) provide Coastal with adequate assurance of future <br />performance in accordance with the provisions of the Agreement. <br />The "default" under the Agreement arises by operation of <br />federal bankruptcy law which prohibits CF&I Steel from pa}~ing <br />certain amounts which arose prepetition without court approval. <br />CF&I Steel, in the Motion, has made a proposal to cure this <br />default amount by payment over time. This payment will fully <br />compensate Coastal for all actual pecuniary loss resulting from <br />CF&I Steel's default. <br />Cf&I Steel has also alleged in the Motion that its credit <br />line and income constitute adequate assurance of its future <br />performance under the Agreement. Richmond Leasing Co. V. Capital <br />Bark, 762 F.2d 1303 (5th Cir. 1985) (debtor corporation's <br />profitability is important factor in determining adequate <br />assurance of future performance). <br />Furthermore, after assumption of the Agreement by CF•5I, any <br />claim that arises under the Agreement becomes an administrative <br />priority. The credit line, cash flow, income, and asset 'oase of <br />4 <br />
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