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180 ton -per -hour FGX-18A dry coal separator system (Serial No. szck20190601 fgxI8a) and the <br />list of addition components attached as Exhibit A hereto. <br />2. On or about July 20, 2020, Castle Valley failed to pay to FGX the 8th monthly <br />installment payment in the amount of $56,601.502. <br />3. As of July 22, 2020 (the "Petition Date"), the amount due to FGX under the Contract <br />is $735,819.50 plus accruing fees, costs, and attorneys' fees3. <br />OBJECTION <br />4. The Debtors recently submitted a notice with the court, Docket No. 236, noting that <br />the anticipated cure claim for the Agreement was $0. <br />As set out above, the correct cure claim amount for the Agreement is $113,203.00 as <br />of August 20, 2020. <br />WHEREFORE, for all reasons set forth herein, FGX respectfully requests that the <br />Debtors' notice as set out in Docket No. 236 be corrected to reflect the true cure amount of the <br />FGX Agreement with Castle Valley. <br />Respectfully submitted, <br />/s/ Billy R. Shelton <br />Billy R. Shelton, Esq. <br />Shelton, Branham, & Halbert PLLC <br />2452 Sir Barton Way, Suite 200 <br />Lexington, KY 40509 <br />Telephone: 859-294-6868 <br />Fax: 859-294-6866 <br />E-mail: bsheltona,sbhlegal.net <br />I After initial down payment(s), the Agreement called for the payment of Twenty (20) monthly installments in the <br />amount of $56,601.50, paid on or before the 20th day of each month. <br />3 13 of the 20 monthly installment payments in the amount of $56,601.50 as set out in the agreement remain <br />unpaid as this time, totaling $735,819.50. <br />