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<br />beneficiary in the amount of $822,000; and (ii) to execute a <br />promissory note, security agreement and certificate of deposit <br />with the Bank to secure the Bank's potential payment obligzition <br />under the letter of credit. In support of this motion, thE: <br />Debtor respectfully represents as follows: <br />1. On November 7, 1990, (the "Petition Date"), <br />Debtor commenced its reorganization case by filing a voluntary <br />petition for relief under chapter 11 of the Bankruptcy Code. <br />2. The Debtor is continuing in possession of its <br />property and is operating and managing its business, as a debtor <br />in possession, pursuant to sections 1107 and 1108 of the <br />Bankruptcy 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 />4. The Debtor and its subsidiaries are substantial <br />enterprises principally engaged in businesses involving the <br />ownership, operation and management of a steel production <br />facility and related businesses located in Utah, New Mexico, <br />Kansas, and Colorado. <br />NATIIRE OF lIOTION <br />5. The Debtor is obligated, pursuant to Federal Law <br />(Mining Control and Reclamation Act of 1977, 30 U.S.C. § 1201 <br />sec.), to perform reclamation work on a mine site owned by the <br />Debtor in Leflore County, Oklahoma (the "Reclamation Site"). <br />2 <br />