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T December 15, 1992 , copies of which are attached to the Proof of 2 Claim, as, respectively, Exhibits H through J. 3 J. As of April 14, 1993 , "Forbearance Fees" and "Additional 4 Forbearance Fees" (as defined in and provided for under the 9/5/91 5 Letter Agreement and the 5/1/92 Letter Agreement, in the aggregate 6 amount of $359, 375. 00 were due and payable as part of the BC 7 Obligations. Additionally, as of November 16, 1993 , Barclays had 8 made additional Protective Advances to or for the account of 9 BC Investment in the aggregate amounts of (i) $104 , 962 . 54 for the 10 payment of real estate taxes on the Real Property Collateral, 11 (ii) $15, 324 . 31 for the payment of insurance premiums with respect 12 to the Real Property Collateral, (iii) $30, 364 . 02 for environmental 13 monitoring, fire protection, and utilities, and (iv) $22 , 383 . 47 for 14 associated legal fees. 15 K. On July 19, 1993 , the Trustee commenced the Adversary 16 Proceeding against Barclays in the Bankruptcy Court. 17 L. Pursuant to the pleadings filed in the Adversary 1e Proceeding, the Trustee seeks a turnover of the Credit Balance, 19 which sum was in the approximate amount of $357 , 103 as of February 20 15, 1994 . Barclays has asserted that the Credit Balance comprises 21 the proceeds of its collateral and that Barclays has the right to a 22 termination of the automatic stay to permit application of the 23 Credit Balance to the BC Obligations. 24 M. The Trustee has collected certain accounts receivable of 25 the Debtor in the aggregate amount of approximately $17 , 160 as of 26 November 22 , 1993 , and anticipates obtaining a default judgment for 27 an additional $7 , 700 in another receivables collection action NOTICE OF JOINT MOTION AND JOINT MOTION FOR ORDER AUTHORIZING COMPROMISE OF CONTROVERSY AND APPROVING STIPULATION FOR RELIEF FROM STAY 5 3435\P006A.LJ C/dcl