In re: NATIONAL STEEL CORPORATION, et al., Chapter 11, Debtors.

Case No. 02-08699, (Jointly Administered)United States Bankruptcy Court, N.D. Illinois, Eastern Division.
April 24, 2003

JOINT STIPULATION AND AGREED ORDER TO LIFT AUTOMATIC STAY FOR MOORE
JOHN H. SQUIRES, United States Bankruptcy Judge

CHARLES MOORE AND PEGGY MOORE (collectively “Moore”), by and through their attorney, John P. Kujawski, and NATIONAL STEEL CORPORATION (“National Steel” or “Debtor”), by and through its attorneys, PIPER RUDNICK, stipulate and agree as follows:

Whereas, Moore has petitioned to lift the automatic stay (Docket Number 543) to pursue its alleged wrongful injury-related claims against National Steel in a case entitled Charles Moore and Peggy Moore v. National Steel Corporation et al., which is pending in the third Judicial Circuit, Madison County, Illinois, as case number 00-L-1304 (the “Case”); and

Whereas, Moore has complied with the Court’s Order regarding the liquidating and setting of personal injury claims (docket #1596).

IT IS HEREBY AGREED, STIPULATED AND ORDERED AS FOLLOWS:

1. The automatic stay is lifted for the limited purpose or allowing Moore to prosecute and liquidate its claims, if any, in the Case against National Steel; and

2. Moore may enforce any judgment it obtains on the foregoing claims against any applicable insurance policy providing coverage for such claims.