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these cases. In support of this Application, the Reorganized <br />Debtors state as follows: <br />1. These Chapter 11 cases were commenced by voluntary <br />petitions filed on November 7, 1990. <br />2. By order entered February 12, 1993 (the "Confirmation <br />order"), this Court confirmed, pursuant to 11 U.S.C. § 1129, the <br />Debtors' and Railroad Trustee's First Amended and Restated Joint <br />Plan of Reorganization Dated December 1, 1992 (the "Plan of <br />Reorganization"). <br />3. Among other things, the Plan of Reorganization <br />established the VEBA. Exhibit C to the Plan of Reorganization <br />provides for payment as administrative expenses in these cases of <br />up to $75,000 of the start-up costs of the VEBA: <br />Professional fees of the Debtors for the <br />establishment of the VEBA will be an <br />administrative expense of the Debtors' <br />estates and other reasonable start-up costs <br />of the VEBA, up to $75,000, but not including <br />any ongoing costs of administration, will be <br />an administrative cost of the estate. Such <br />fees and costs will be subject to the review <br />and approval of CFSI, New CF&I, and the <br />Creditors' Committee, which will not be <br />unreasonably withheld, and to the review and <br />approval of the Court. <br />4. The Effective Date of the Plan of Reorganization <br />occurred on March 3, 1993. <br />5. Pursuant to the Court's "Order Granting Motion for <br />Approval of Revised Provisions for Post-Effective Date Governance <br />of Reorganized Debtors," signed on July 28, 1993, and entered on <br />7 <br /> <br />2 <br />