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1992 Plan. The Reorganized Debtors will submit a motion <br />requesting the approval of this Agreement and the allowance of <br />the Administrative Claim. On the Closing Date, the Reorganized <br />Debtors will pay $800,000, in full satisfaction cf the <br />Administrative Claim, as may be directed at closing by the <br />Combined Fund and the 1992 Plan. <br />(b) Dismissal of Adversary Proceeding. CF&2 Steel <br />and the Combined Fund will submit a proposed stipulation <br />substantially in the form attached hereto as Exhibit B for <br />dismissal of the Adversary Proceeding with prejudice. <br />(c) Claims and Claim Objections. The Reorganized <br />Debtors, the Combined Fund, and the 1992 Plan will request that <br />the Bankruptcy Court, as part of the Approval Order, approve the <br />amendment of the Claims filed by the Combined Fund and the 1992 <br />Plan to $fl00,000 as specified above in subparagraph 2(a) and the <br />dismissal of the Claim Objections filed by the Reorganized <br />Debtors. <br />(d) Dismissal of Appeals. The Combined Fund, the <br />1992 Plan and the Reorganized Debtors will submit to the District <br />Court a proposed stipulation substantially in the form attached <br />hereto as Exhibit C for dismissal of the District Court Appeals. <br />The Combined Fund, the 1992 Plan and the Reorganized Debtors will <br />submit to the Tenth Circuit a proposed stipulation substantially <br />in the form attached hereto as Exhibit D for dismissal of the <br />Tenth Circuit Appeals. <br />(e) Joint Reouest for Withdrawal and yacatur of the <br />Estimation Order. The Reorganized Debtors, the Combined Fund, <br />and the 1992 Plan will use their best efforts to obtain the <br />7 <br />