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<br />encumbrances, pursuant to 11 U.S.C. §§ 363, 1123(b)(5j +snd <br />1141(c), for the sum of $2,000,000 plus a dollar amount for <br />inventory to be calculated at or near closing.. In support of <br />this Motion, the Reorganized Debtors respectfully represent as <br />follows: <br />1. 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(bj(2j. <br />2. On February 12, 1993 (the "Confirmation Date"j, the <br />Covrt entered an order confirming the Reorganized Debtors' First <br />Amended and Restated Plan of Reorganization (the "Plan"j. <br />3. The Plan, at paragraph 53, provides that <br />All property of the Debtors or the Debtors' estates not sold <br />under the Asset Purchase Agreement,shall be used, sold, or <br />leased in an ordeily manner using such methods as are <br />appropriate in the discretion of the Reorganized Debtors to <br />obtain for holders of Claims, entitled to distributions out <br />of such property,. the; highest:_net.value.f;om such remaining <br />assets within a reasonable period of .time.. <br />4. The Plan, at page 14, describes the assets to be <br />sold and provides that the net proceeds of their sale will be <br />used to fund the Appeal Fund described in the Plan. <br />5. The Plan further provides, at paragrapY~ 76, for <br />the retention of property by each of the Reorganized Debtors. <br />The Plan further provides, at page 12, that after the Plan's <br />effective date, each Reorganized Debtor shall operate or <br />liquidate its remaining assets. <br />2 <br />