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<br />,~ accidental injury claims arising after September 14, 1985 (the <br />"Post-September 1985 Claims"), the Self-Insured Debtors have <br />purchased a certificate of deposit, X300867, in the amount of <br />$870,000 from Colorado National Bank of Denver.Z For claims in ~ <br />excess of $300,0003 per injury, the Self-Insured Debtors have an <br />excess insurance policy with Transamerica Insurance Company. <br />6. As of the Petition Date, there were outstanding <br />Pre-September 1985 Claims in the approximate amount of $2,456,000 <br />and Post-September 1985 Claims in the approximate amount of <br />$820,000. These numbers include some estimated amounts for <br />claims which have been filed, but which have not yet been finally <br />determined or adjudicated. <br />7. On November 7, 1940, the Debtors filed an emergency <br />motion seeking an order authorizing the Self-Insured Debtors to <br />continue to pay all Post-September 1985 Claims, whether such <br />claims have been determined or adjudicated or are determined or <br />adjudicated in the future. At a hearing on November 7, 1990, <br />the Court authorized the Self-Insured Debtors to pay up to <br />2. The amount of such certificate of deposit or other security <br />instrument is subject to annual reevaluation and change in light <br />of changes in number and amount of workers' compensation claims <br />asserted against the Self-Insured Debtors. <br />3. This amount has varied from $200,000 to $300,000. <br />4. As set forth in the motion and memorandum filed by the <br />Debtors on November 7, 1990, the Debtors' believe that payment of <br />Post-September 1985 Claims (and other claims for employee <br />benefits) is critical to the Debtors' reorganization efforts <br />because, 'ni ter a a, it allows the Debtors to maintain cost <br />effective self-insurance for workers' compensation d2aims, <br />bolster employee morale and confidence, and maintain a good <br />working relationship with the union. <br />4 <br />