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GENERAL43723
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Last modified
8/24/2016 8:12:33 PM
Creation date
11/23/2007 12:36:54 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
General Documents
Doc Name
US BANKRUPTCY COURT DMG OBJECTION TO THE LENDERS MOTION FOR ADEQUATE PROTECTION AND FOR RELIEF
Permit Index Doc Type
GENERAL CORRESPONDENCE
Media Type
D
Archive
No
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<br />Machinery and Equipment. The Lenders contend that all of <br />Machinery and Equipment is encumbered with their various liens <br />and that their interest in the Machinery and Equipment is <br />superior to that of any other party, including Creditor <br />Colorado Division of Minerals and Geology. <br />The Lenders are not entitled to the relief they seek. <br />First, under, inter alia., 28 U.S.C. 6 959(b), the Debtor <br />Powderhorn is required to comply with reclamation and <br />environmental remediation statutes and regulations, and the <br />proceeds of the sale of the Machinery and Equipment are <br />necessary for the Debtor Powderhorn to fulfill its reclamation <br />and environmental remediation obligations. <br />Second, the Debtor Powderhorn needs the proceeds of the <br />sale of the Machinery and Equipment to fund the reclamation. <br />The reclamation will render the Debtor Powderhorn's real <br />estate, which is also encumbered with the Lenders' lien, <br />salable. Therefore, using the Machinery and Equipment <br />proceeds to clean up the real estate constitutes a reasonable <br />and necessary cost of preserving and disposing of the real <br />Creditor Colorado Division of Minerals and Geology has not yet filed a proof <br />of claim. Once it does, the Proofs of Claim in Case Nos. 00-51389 and 00- <br />51385 will probably list the claim as contingent and unliquidated. <br />4 <br />
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