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1 This Motion is based upon this Notice of Motion and <br /> 2 Motion, the records and pleadings on file in the Adversary <br /> 3 Proceeding and other actions referenced herein, and in this <br /> 4 Chapter 7 case, such further oral and documentary evidence as may be <br /> 5 presented at any hearing on this Motion, and the foregoing facts and <br /> 6 circumstances. <br /> 7 WHEREFORE, the Trustee and Barclays respectfully request <br /> 8 this Court to enter an order: <br /> 9 1. Approving the Settlement Agreement; <br /> 10 2 . Granting Barclays' relief from the automatic stay, <br /> 11 thus allowing Barclays to apply the Credit Balance to the <br /> 12 BC Obligations, as defined herein; <br /> 13 3 . Finding that the Settlement Agreement between the <br /> 14 Trustee and Barclays is reasonable and in the best interests of the <br /> 15 estate, and that notice of this Joint Motion is proper under the <br /> 16 circumstances pursuant to Rules 2002 (a) (3) , 2002 (i) and 4001 (d) of <br /> 17 the Federal Rules of Bankruptcy Procedure; and <br /> 1s <br /> 19 <br /> 20 <br /> 21 <br /> 22 <br /> 23 <br /> 24 <br /> 25 <br /> 26 <br /> 27 <br /> NOTICE OF JOINT MOTION AND JOINT MOTION FOR <br /> ORDER AUTHORIZING COMPROMISE OF CONTROVERSY AND <br /> APPROVING STIPULATION FOR RELIEF FROM STAY 13 3435\P006A.LJC/dcl <br />