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1 (collectively, the "Account Collections") . Other pre-petition 2 receivables exist; however, the Trustee has informed Barclays that 3 these may prove of negligible value. Barclays asserts that all 4 accounts receivable and their proceeds held by the Estate, including 5 the Account Collections, are collateral in which Barclays held a b perfected security interest under the Security Documents as of the 2 Petition Date. 8 N. The Trustee has collected the refund of a professional 9 legal retainer paid out pre-petition by the Debtor in the 10 approximate amount of $10, 175 .44 and may receive a further refund of 11 as much as $5, 000 (collectively, the "Refunds") , which Refunds, but 12 for the settlement hereunder, Barclays would assert to be the 13 proceeds of its collateral as the proceeds of accounts receivable 14 and general intangibles and/or monies in which Barclays held a 15 perfected security interest under the Security Documents. 16 0. On or about October 23 , 1993 , Barclays assigned to its 17 affiliate, ITL-Cross, all right, title, interest, and obligation of 18 Barclays in the loan, security, and related documents evidencing and 19 securing Barclays' claim in the Chapter 7 Case. 20 P. On November 18 , 1993 , the Real Property Collateral was 21 foreclosed by nonjudicial sale pursuant to the Deed of Trust and 22 after no third-party bid was received, ITL-Cross became the owner 23 thereof by reason of its credit bid in the amount of $2 , 100, 000. 24 Barclays acknowledges that the foregoing credit bid reduces in that 25 amount the BC obligations, which Barclays computes as approximately 26 $3 ,475, 000 immediately preceding the foreclosure sale. Accordingly, 27 after reduction by reason of the credit bid, the BC Obligations, and NOTICE OF JOINT MOTION AND JOINT MOTION FOR ORDER AUTHORIZING COMPROMISE OF CONTROVERSY AND APPROVING STIPULATION FOR RELIEF FROM STAY 6 3435\POObA.LJC/d[l