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<br />a. The Combined Fund and the 1992 Plan shall have a <br />combined allowed administrative claim of $800,000, which will be <br />divided equally between them. They may amend the claims they <br />previously filed to reflect this allowed administrative claim. <br />b. The Reorganized Debtors will withdraw with <br />prejudice the Claim Objections and the Combined Fund and 1992 Plan <br />will amend the claims they filed and agree that they will have no <br />claims against the Reorganized Debtors other than the <br />administrative claim of $800,000 as set forth in the Settlement <br />Agreement. <br />c. Reorganized CF&I Steel Corporation and the <br />Combined Fund will stipulate to the dismissal with prejudice of <br />the Adversary Proceeding and will request that this Court approve <br />their stipulation. They will also request that the UMWA, which is <br />also a defendant in the Adversary Proceeding, stipulate to the <br />dismissal with prejudice of the Adversary Proceeding. <br />d. The Combined Fund, the 1992 Plan, and the <br />Reorganized Debtors will jointly stipulate to the dismissal of all <br />appeals filed by the Combined Fund and the 1992 Plan in the <br />Reorganized Debtors' cases and will request the District Court and <br />the Tenth Circuit, as appropriate, to approve their stipulations <br />and dismiss these appeals. <br />e. The parties will request the District Court to <br />order this Court to vacate and withdraw the Estimation Order. <br />f. The parties will execute mutual releases. <br />7 <br />