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<br />• which is equal or superior to that granted to Congress herein; <br />unless in each instance (i) Congress shall have given its express <br />prior written consent thereto, or (ii) such other order requires <br />that there shall first be indefeasibly paid in full to Congress <br />the Congress Indebtedness and all other debts and obligations of <br />Debtors to Congress which arise or result from the obligations, <br />loans, credit, security interests, and liens authorized by the , <br />Financing Order. The security interests and liens granted to <br />Congress and the rights of Congress pursuant to the Financing <br />Order with respect to the Congress Indebtedness and the <br />Collateral shall not be altered, modified, extended, impaired, or <br />affected by any plan of reorganization of any of Debtors and <br />shall continue after confirmation and consummation of any such <br />plan. <br />(11) The Financing Agreements require the <br />Debtors to submit to the non-exclusive jurisdiction of the state <br />and federal courts in California and in any other State in which <br />the Collateral is located. <br />IV. H71BI8 FOR BELIEF REQIIEBTED <br />13. The need for the proposed Financing Agreements is <br />compelling. Accounts receivable financing is essential to the <br />maintenance of normal operations. The Debtors need to pledge <br />their receivables in order to maintain sufficient cash flow to <br />permit them to pay vendors on strict credit terms imposed because <br />of the Debtors' financial difficulties. If the Debtors are <br />unable to draw on a financing facility, their cash flow will <br />15 <br />