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<br /> <br />INTRODIICTION <br />1. The Debtors' continued successful operation depends <br />upon maintaining a steady stream of manufactured products, which <br />in turn requires that the Debtors be able to purchase necessary <br />materials from their vendors. Because of the Debtors' financial <br />difficulties, many of their vendors have imposed stringent credit <br />terms including payment on delivery.. These inflexible credit <br />terms required by the Debtors' vendors have created cash flow <br />difficulties. The Debtors need an accounts receivable financing <br />facility to permit them to pledge their receivables and create <br />sufficient cash flow to continue their manufacturing operations. <br />The Debtors also need postpetition financing to permit them to <br />retain vendor and customer confidence that they have the <br />financing necessary to continue their business. The availability <br />of postpetition financing is therefore essential to the Debtors' <br />continued successful operations. The ability of Debtors to <br />continue in business and remain viable entities and thereafter <br />reorganize under Chapter 11 of the United States Bankruptcy Code, <br />11 U.S.C. §§ 101 et sec. (the ^Bankruptcy Code") depends upon <br />obtaining the financing proposed by this Motion. <br />2. This motion asks the Court to approve, after notice <br />pursuant to Bankruptcy Rule 4001 and a full hearing, a new <br />postpetition financing agreement of up to $10,000,000 between the <br />Debtors and Congress. The Debtors do not currently intend to ask <br />for interim financing. <br />3 <br />