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<br /> <br />6. CF&I Steel believes that the Reclamation Claimants <br />listed on Exhibit A to the Memorandum have some valid reclamation <br />claims against it with respect to goods sold. CF6I also believes <br />that Reclamation Claimants not listed on Exhibit A do not hold <br />valid reclamation claims against it with respect to goods sold. <br />7. The monetary value of all valid reclamation rights <br />of the Reclamation Claimants is indicated in the Column in <br />Exhibit A entitled "Court Approval." Thus, the Reclamation <br />Claimants who appear on Exhibit A with an amount corresponding to <br />such claimant indicated in the "Court Approval" column have valid <br />reclamation rights against CFbI Steel. The total of these valid <br />reclamation claims is $358,252.48. <br />8. Certain of the Reclamation Claimants listed in <br />Exhibit A have asserted reclamation claims which, after analysis <br />by CF&I Steel and in CF&I Steel's opinion, are invalid under the <br />criteria explained in the Memorandum. The monetary values of the <br />invalid reclamation claims of the Reclamation Claimants listed on <br />Exhibit A are indicated in the column in Exhibit A entitled <br />"Invalid Claims." <br />9. CF&I asks that the invalid reclamation claims of <br />those persons listed in Exhibit A should be disallowed either as <br />affording the Reclamation Claimants any rights tc reclamation of <br />goods or as giving rise to a priority claim under sections 546(c) <br />or 503 (b) of the Bankruptcy Code against the bankruptcy estate of <br />CF&I Steel. The basis for the disallowance of each such claim is <br />set forth in the accompanying memorandum. <br />3 <br />