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,~; <br />this Motion, the Reorganized Debtors respectfully represent as <br />follows: <br />1. On May 21, 1993, the Reorganized Debtors filed a <br />motion seeking the approval of the sale of the Property, Plant <br />and Equipment formerly owned by Albuquerque Metals to Acme for <br />the total purchase price of $900,000 (the "Motion"). <br />2. Notice of the hearing on the Motion was sent on <br />May 24, 1993. The hearing was set for June 28, 1993. Parties <br />were required to respond in writing to the Motion by June 18, <br />1993. <br />3. Attached to the Motion as an exhibit was the <br />Purchase Agreement between the Reorganized Debtors and Acme which <br />embodies the terms and conditions of the sale of the Property, <br />Plant and Equipment to Acme. <br />4. Paragraph 5 of the Purchase Agreement allowed for <br />an environmental inspection by Acme and allowed Acme, depending <br />upon the results of that inspection, to terminate the Purchase <br />Agreement. <br />5. Acme has completed the inspection and has found <br />certain environmental problems. Instead of terminating the <br />Purchase, Agreement, however, Acme has proposed, and the Debtors <br />have accepted, a reduction to the purchase price to account for <br />the environmental problems. The addendum attached hereto <br />includes the required revisions to the original Purchase <br />2 <br />