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I therefore, the amount of ITL-Cross' claim under the Proof of Claim, z were reduced to approximately $1, 375, 000 as of November 18, 1993 . 3 Q. On or about December 31, 1993 , Barclays' affiliate, ITL- 4 Cross, sold the Real Property Collateral to an independent, third- s party buyer for an "all-cash" net price of $1, 800, 000, and Barclays 6 has so informed the Trustee. 7 R. By reason of all of the foregoing, Barclays and ITL-Cross a have informed the Trustee that they have liquidated the Real 9 Property Collateral and reduced the BC Obligations, all pursuant to 10 the terms of the agreements between Barclays, BC Investment, and the II Debtor, and, accordingly, believe that the automatic stay should be Iz lifted to permit application of the Credit Balance, as the proceeds 13 of Barclays' collateral, in order to further reduce the BC 14 Obligations. 15 S. The Trustee, on the one hand, and Barclays and ITL-Cross, 16 on the other hand, desire to fully settle, compromise and resolve 17 all claims asserted or which might have been asserted in the Is Adversary Proceeding and any and all debts, claims, demands and 19 causes of action of any nature whatsoever, heretofore or hereafter 20 arising out of or in connection with the Loan and Security Agreement ZI and all associated documents, the Security Documents, the Credit zz Balance, Debtor's business operations, the foreclosure of the Real 23 Property Collateral and certain improvements thereto made by the 24 Debtor pre-petition, the Chapter 7 Case, and all matters directly or 25 indirectly related thereto, upon the terms and conditions set forth 26 below, for the purpose of avoiding the burden, expense and 27 NOTICE OF JOINT MOTION AND JOINT MOTION FOR ORDER AUTHORIZING COMPROMISE OF CONTROVERSY AND APPROVING STIPULATION FOR RELIEF FROM STAY 7 3435\P006A.LJC/dcl