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claims; (3) granting a priority claim pursuant to 11 U.S.C. §g <br />503(b) a:nd 546(c)(2)(A) in favor of the entities with valid <br />reclamation claims against CF&I Steel Corporation; and (4) <br />allowing CFSI steel Corporation to pay such priority claims. In <br />support of this motion, the Debtor states as follows: <br />BACKGROUND <br />1. on November 7, 1990, (the °Petition Date°), C1'~I <br />Steel coaunenced its reorganization case by filing a voluntary <br />petition for relief under chapter 11 of the Bankruptcy Code. <br />2. CF&I Steel is continuing in possession of its <br />property and is operating and managing its business, as a det~tor <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). <br />4. CF&I Steel is a substantial enterprise principally <br />engaged ire the ownership, operation and management of a steel <br />production facility and related businesses located in Utah, New <br />Mexico, Ita~nsas and Colorado. <br />RECLAMATION CLAIMS <br />5. Certain sellers of goods to CF3I Steel have made <br />written demand for reclamation upon CF&I Steel (the "Recla~mati.on <br />Claimants"). Some of the Reclamation Claimants are listed in <br />Exhibit A attached to the memorandum accompanying this Motion <br />(the "Memorandum"). <br />2 <br />