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<br />trustees of the VEBA, Debtors have given notice to the IIr.~it~_d <br />Steelworkers of America and Oregon Steel lSi115, Inc., and, have <br />been advised that such parties have no objection to Mr. Fea:rson's <br />appointment or to this Court's consideration of his appoint~¢ent <br />on an ex arte basis. <br />12. No provision of the Plan, the Bankruptcy Code or i•.he <br />Bankruptcy Rules requires prior notice of this matter to parties <br />in interest. <br />13. Accordingly, Debtors' believe this matter may be <br />considered by the Court on an ex carte basis. <br />14. Paragraph 66 of the Plan provides: "The Debtors ar.~d the <br />Reorganized Debtors shall be <br />judgments, injunctions, and <br />to those specifically listed <br />carry out the intentions and <br />shall retain jurisdiction to <br />injunctions, and rulings." <br />entitled to seek such orders, <br />rulings from the Court, in adciition <br />in the Plan, as nay be neces:>ary to <br />purposes of the Plan. The Court <br />enter such orders, judgments, <br />15. Paragraph 86(d) of the Plan provides that the Caurt <br />will retain jurisdiction t~ "enter orders in aid of or to <br />interpret the Plan." <br />16. Accordingly, Debtors believe the Court has jurisdirtion <br />to enter the order requested herein. <br />WHEREFORE, Debtors request that the Court enter an ordez- in. <br />the form submitted herewith appointing Mr. Pearson, place ~of Mr. <br />4 <br />