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5. A listing of all cases in which a Notice of Automatic <br />Stay was filed by CF&I is attached as Exhibit 3. <br />6. Pursuant to the provisions of 11 U.S.C. §362(b)(4), <br />the processing and adjudication of Worker's Compensation claims <br />is a valid exercise of the State's police or regulatory powers. <br />This motion is not advanced for purposes of advancing the State's <br />pecuniary interest. <br />7. Alternatively, motion is made for relief from stay pur- <br />suant to 11 U.S.C. §362 (d)(2). As stated above, for pre- <br />September, 1985 claims, Fireman's Fund Insurance Company issued <br />a Guaranty Bond for Self-Insuring Employers, which Bond applies <br />by its terms to all past liability and to all liability that was <br />at that time present existing and potential liability of CF&I <br />Steel Corporation as a self-insurer to the extent of the amount <br />of the bond. For periods after September 14, 1985, CF&I Steel <br />Corporation was self-insured in Colorado pursuant to the above <br />referenced Self-Insurance Trust Agreement in which was deposited <br />by the Executive Director of Labor and Employment a Certificate <br />of Deposit dated March 9, 1987 issued by the Colorado National <br />Bank of Denver in the name of the Executive Director of Labor and <br />Employment of Colorado for use to pay CF&I Steel Corporation <br />Worker's Compensation Claims cost. Based on the nature of the <br />Guaranty Bond issued by Fireman's Fund Insurance Company, and the <br />Reserve Trust Agreement, cause is established for relief from the <br />automatic stay for worker's compensation claims, and there will <br />be no adverse impact on Debtor's estate. <br />WHEREFORE, the Director, Division of Labor, Colorado <br />Department of Labor and Employment, respectfully requests that <br />this Court enter its Order granting relief from the automatic <br />stay provisions of 11 U.S.C. §362 to allow the processing and <br />adjudication of worker's compensation claims under applicable <br />Colorado law. <br />GALE A. NORTON <br />Attorney General <br />RAYMOND T. SLAUGHTER <br />Chief Deputy Attorney General <br />TIMOTHY M. TYMKOVICH <br />Solicitor General <br />PAUL FARLEY <br />Deputy Attorney General <br />-3- <br />