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t <br />II. PARTIES 71ND JIIRIBDICTION <br />8. On November 7, 1990 (the ^Petition Date"), the <br />Debtors commenced their reorganization cases by filing voluntary <br />petitions under chapter 11 of the Bankruptcy Code. <br />9. The Debtors are continuing in possession of their <br />properties and are operating and managing their businesses as <br />debtors in possession pursuant to the 11 U.S.C. §§ 1107 and 1108. <br />10. This Court has jurisdiction pursuant to 28 U.S.C. <br />55 157 and 1334 and this is a core proceeding under 28 U.S.C. <br />55 157(b)(2)(A) and (M). <br />III. pROPOBED POBTPETITION FINANCING <br />11. As debtors in possession, the Debtors need an <br />accounts receivable financing facility to meet their ongoing cash <br />and credit requirements during their chapter 11 cases, and to <br />ensure vendor and customer confidence. Without the financing <br />proposed by this Motion, Debtors may not have the funds necessary <br />to meet payroll, purchase inventory, and pay other expenses <br />necessary for the continued operation of their respective <br />businesses and for the management and preservation of their <br />respective properties. With the financing proposed by this <br />Motion, which will become effective only upon authorization from <br />this Court, the Debtors will be able to meet necessary operating <br />expenses, to continue operations by being able to receive from <br />vendors materials necessary to their manufacturing operations, <br />and to maximize profitability. <br />5 <br />