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secured claim by United Bank is collateralized by a certificate <br />of deposit in the possession o! United Bank. <br />b. Payment under the Letter of Credit may lend to <br />litigation by Debtor for return of amounts to which OSI+DtE :is not <br />entitled. Besides the uncertainty o! the results of the <br />litigation, the litigation costs could not be recovered. <br />11. Debtor can avoid this irreparable harm only if it is <br />permitted to renew the Letter o! Credit forthwith. IInited Bank <br />is willing to renew the Letter of Credit on essentially the same <br />terms and conditions, including security arrangement, currently <br />in effect between Debtor and IInited Bank. <br />12. The financing contemplated by the Verified Notion <br />require the execution and delivery o! financing and eecuri.ty <br />agreements, documents, and instruments (the "Financing <br />Documents") as set forth in the Verified Notion and as submitted <br />to the Court. Rey provisions of the Financing Documents are eet <br />forth in the Verified Notion and in the draft Financing Documents <br />submitted to the Court. The only differences between the terms <br />as summarized in the verified Notion and the terms of the <br />Financing Documents are (a) that no interest is payable under the <br />Note until a draft is made on the Letter of Credit and (b) the <br />fee for issuing the Letter of Credit payable at closing i.s <br />56,165.00. <br />13. Debtor believes that the proposed Financing Lbcuments <br />reflect the exercise of sound and prudent business judgment and <br />have been negotiated in good faith. <br />