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<br /> <br />CF&I is seeking contamporaneously wish the approval of the EPA SUtlement Agrament. <br />Assuming Bankruptcy Court approval of Ne Coverage Action Settlements is obtained and all <br />sums are paid in accordance with the Coverage Action Settlements, Reorganirtd CF&1 will <br />ret~ve net settlement procads of (4,300,000,' <br />12. On February 8, 1993 the EPA filed Responu Of United Subs on <br />Behalf of EPA to Motion By CFdcl Steel Corporation Dated (/25/93 for Order Approving (U <br />Settlement Agrament Betwlxn CFdrI Steel Corporation, Crane Company and Various <br />Insurance Companies And (2) Allocation Agreement BUwan CFkI Stal Corporation and <br />10. On al least two aerations the EPA has taken Ne position before This Crane Company (the 'EPA's ObjaSon to American Home/Cnne Settlements'). In the <br />Court Nal Ihe EPA has an equiable interest in and is enfitled to any insurance prooxds That EPA's Objation to Ameripn Home/Crane Settlements, the EPA again argued that it had an <br />may be raovered in tronnection wish Ihe Coverage Action. ~ equiable interest in any insurance proceeds rsicovered in connection with the Coverage <br />11. On or about January 18, 1993 Ne EPA filed Objation Of United Stiles ~ Acton, however, the EPA urged Nat until the Coverage Acion was completely resolved the <br />On Behal(Of EPA To First Amended and Resisted Joint Plan of Reorganirs5on Dated amount of Ihe EPA's equitable interul in such insurance proceeds should not be rewlved, <br />12/1/92 (the 'EPA's Objation to Confirmation'). Generally, Ne subsrana of Nc EPA's but that Reorganired CF&1 should be pnxludad from distributing any such pocads. <br />ohjatian waz Uut the DWtori Plan proposed to use insusance poaeeds from the Coverage Thereafter, the EPA filed a Withdrawal at Response of United Stites on Behalf of EPA to <br />Action to pay general unsecured creditors ether Nan using such proaods to pay the party to Motion By CF&I Steel Corporation Dated 1/25/93 for Order Approving Senlement and <br /> <br />whom CF&1 was legally obligated for property damage, i.e. Ne EPA. The Court ovemSlexl I <br />I Allocation Agreements Regarding Insurance. On March 2, 1993 Ne Court entere4 its Order <br />Ne FPA's Objation to Confirtnalion on Ne grounds Nat to Ne extent EPA has any interest Approving Motion Filed Under Seal by CFdcl Corporation, Dated 1/25/97, for Order <br />in Ne insurance proceeds, 'Nat interest in not being aflated by Ne Plan'. Sa espies of Approving (1) Settlement Agrament BUwan CFAcI Skel Corporation and Crane Company <br />pages 80 and 81 of the transcript of Ne Court's Statemenu from Ne Bench at Ihe January ~ and American Home Assurance Company, Granite Stile Insurence Company, National Union <br />27, 1992 confirmation hearing on Debtors' Plan o(Reorganimlion, a copy of which is Firc Insunna Company of Pittsburgh, Pennsylvania, AIU Insunna Company, and <br />attached hemo az Exhibit 2. Lexington Insurance Company, and (2) Alloation Agreement Betwan CF&I Stal <br /> Corporation and Crane Company and Objation to Seal Order Dated 01/22193. <br />'The aggregate gross Senlement amount is 54,50(1,000, however, one of Ne Insurance <br />Companies is entitled, pursuant to Ne settlement agreement wiN Thal Insurance Company, to <br />draw on letters of credit provided by CFdtl in the amount of (100,000, Hereby reducing the <br />eel settlement to E4,300,000. <br />-5- -5- <br />I , <br />