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J ~ <br />~f <br />representations contained in paragraph 7 respecting a ra~.e <br />reduction in the executory contract with Coastal. In support of <br />this t4otion, CF&I Steel respectfully represents as follo'ds: <br />Background <br />1. On November 7, 1990, (the "Petition Date"), CF&2 <br />Steel commenced its reorganization case by filing a voluntary <br />petition for relief under chapter 11 of the Bankruptcy Code. <br />2. CF&I Steel is continuing in possession of its <br />property and is operating and managing its business, as a debtor <br />in possession, pursuant to sections 1107 and 1108 of the <br />Bankruptcy Code. <br />3. The Court has jurisdiction over this matt~_r <br />pursuant to 28 U.S.C. §§ 157 and 1334. This is a core proceeding <br />pursuant to 28 U.S.C. § 157(b)(2). <br />4. CF&I Steel is a substantial enterprise principally <br />engaged in the ownership, operation and management of a steel <br />production facility and related businesses located in Utah, New <br />Mexico, Kansas and Colorado. <br />Description of the Gas Contract <br />5. CF&I Steel and Coastal are parties to a Gas Sales <br />Agreement dated September 1, 1990 (the "Agreement"). Under the <br />Agreement, CF&I Steel purchases from Coastal the natural gas <br />requirements for its Pueblo, Colorado steel manufacturing <br />facility up to a specified daily maximum amount. Under t:he <br />Agreement, Coastal is obligated to deliver natural gas at: a fixed <br />price until September 30, 1991, and thereafter at a price based <br />upon a formula contained in the Agreement. As explained below <br />2 <br />