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4 <br /> <br />eliminated. The Debtors have entered into an agreement with <br />Congress Financial Corporation (Western) ("Congress") for <br />.510,000,000 in postpetition financing secured by a first lien on <br />accounts receivable, inventory, general intangibles, and other <br />personal property. The terms of this proposed financing as well <br />as related relief are set forth in the Motion and the Financing <br />Agreements attached to the Motion. <br />II. ARGIIMENT <br />Chapter it reorganization is premised on the view that <br />reorganization of a going concern is generally preferable to <br />liquidation. Creditors are generally benefited by maintaining <br />the value of a large concern through reorganization. As Judge <br />Howard Buschman recently noted, <br />It is given that most successful reorganizations <br />require the debtor-in-possession to obtain new <br />financing simultaneously with or soon after the <br />commencement of the Chapter 11 case. <br />In re Ames Dent. Stores. Inc., 115 Bankr. 34, 37 (Bankr. S.D.N.Y. <br />1990). It is critical that the Debtors receive immediate <br />financing because new lenders have been unwilling, given the <br />Debtors' large pension obligations, to advance loans to them <br />until they had filed cases under chapter 11. The Debtors' <br />vendors have restricted their credit dramatically. Under these <br />circumstances, the Debtors can no longer continue operations <br />without receivables financing. <br />The Debtors' obtaining financing as set forth in the Motion <br />will benefit the Debtors and their creditors by permitting the <br />3 <br />