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day. The amount of the Credit Balance was approximately $357, 103 as of February 15, 1994. I. Barclays subsequently made further financial accommodations to BC Investment (the "Protective Advances") which increased the amount of the BC Obligations. The Protective Advances have been made to preserve and realize the value of the Real Property Collateral and thereby ultimately minimize Debtor's obligations, as more fully described below, in the 4/9/91 Letter Agreement, and in those other letter agreements between BC Investment and Barclays (collectively, the "BC Letter Agreements") dated, respectively, September 5, 1991 (the 119/5/91 Letter Agreement") , May 1, 1992 (the 115/1/92 Letter Agreement") and December 15, 1992, copies of which are attached to the Proof of Claim, as, respectively, Exhibits H through J. J. As of April 14, 1993, "Forbearance Fees" and "Additional Forbearance Fees" (as defined in and provided for under the 9/5/91 Letter Agreement and the 5/1/92 Letter Agreement, in the aggregate amount of $359, 375. 00 were due and payable as part of the BC Obligations. Additionally, as of November 16, 1993 , Barclays had made additional Protective Advances to or for the account of BC Investment in the aggregate amounts of (i) $104 , 962. 54 for the payment of real estate taxes on the Real Property Collateral, (ii) $15, 324. 31 for the payment of insurance premiums with respect to the Real Property Collateral, (iii) $30, 364. 02 for environmental monitoring, fire protection, and utilities, and (iv) $22, 383 . 47 for associated legal fees. K. On July 19, 1993, the Trustee commenced Adversary Proceeding No. 93-9126 (the "Adversary Proceeding") against Barclays in the Bankruptcy Court. L. Pursuant to the pleadings filed in the Adversary Proceeding, the Trustee seeks a turnover of the Credit Balance, which sum was in the approximate amount of $357, 103 as of February 15, 1994 . Barclays has asserted that the Credit Balance comprises the proceeds of its collateral and that Barclays has the right to a termination of the automatic stay to permit application of the Credit Balance to the BC Obligations. M. The Trustee has collected certain accounts receivable of the Debtor in the aggregate amount of approximately $17, 160 as of November 22, 1993 , and anticipates obtaining a default judgment for an additional $7,700 in another receivables collection action (collectively, the "Account Collections") . Other pre-petition receivables exist; however, the Trustee has informed Barclays that these may prove of negligible value. Barclays asserts that all accounts receivable and their proceeds held by the Estate, including the Account Collections, are 3435NA002F.MP8 3