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<br />3. The creditors' matrix on file with the court currently <br />exceeds thousands of creditors and parties in interest. <br />4. Nemo believes that under the circumstances, notice to <br />all creditors as required by Bankruptcy Rule 6007(a) is <br />unnecessary and unduly burdensome. <br />5. Nemo requests that notice on its Motion be reduced to <br />those entities listed in Exhibit "A" attached hereto, which is a <br />shortened matrix (Master Service List No. 9) prepared by Debtor's <br />counsel and approved by the court on or about June 11, 1991. <br />WHEREFORE, Nemo prays that notice required by Subsection (a) <br />of Rule 6007 of the Bankruptcy Rules be limited to the following: <br />a. Creditors, the U. S. Trustee, and parties in <br />interest as contained in Exhibit "A" and their respective counsel <br />who have filed a written request for notice oz a written entry of <br />appearance with the Bankruptcy Court and served a copy thereof <br />upon Debtor's counsel. <br />DATED this /3 day of June, 1991. <br />Noel S. Hyde <br />Steven F. Allred <br />NIELSEN fi SENIOR <br />Attorneys for Nemo Ore Company <br />1100 Eagle Gate Tower <br />60 East South Temple <br />Salt Lake City, Utah 84111 <br />9973.GR651.MDD <br />-2- <br />