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<br />addition, the estate was charged for a payment of $26.40 to the <br />Jefferson County Clerk for license plates on Ms. Braley's personal <br />car, together with insurance on that car. <br />5. These listed items have nothing to do with the bankruptcy <br />estate, are Dena Braley's personal expenses, and should not be <br />charged. This would reduce the proper amount subject to <br />stipulation to $63,676.14. <br />6. In addition, the stipulated amounts include a total of <br />$6,785.45 for payment of expenses for Braley Sand & Gravel, Inc. <br />There is no indication why this would be a proper expense of the <br />estate of Jimmie Dean Braley, Sr., individually. Subtracting these <br />amounts out reduces the allowable claim to $56,890.69. <br />7. It further appears that Ms. Braley did not obtain <br />contemporaneous documentation for any of the advances purportedly <br />made to the Debtor, Jimmie Dean Braley. While there are unsigned <br />loan and security documents, nothing was actually recorded on these <br />various claims until after the filing of the bankruptcy in March, <br />1995. For this reason, it may be concluded that these various <br />"advances" were a gift, and that there was no intention to enforce <br />repayment. For this reason, the claim should be disallowed in <br />full. <br />For all of the forgoing reasons, Darlene Fehr asks that this <br />Court set a hearing and disallow the stipulation and deny the joint <br />motion to settle the adversary proceeding. <br />T~+ <br />Respectfully submitted this S day of May, 1997. <br />ANRELE~ ICENOGLE~ NORTON, WHITE E BETER <br />A Professional Corporation <br />~. <br />Charles E. Norton, #10633 <br />5690 DTC Boulevard, Suite 300 <br />Greenwood Village, CO 80111 <br />(303) 773-1666 <br />ATTORNEYS FOR DEBTOR DARLENE J. FEHR <br />CERTIFICATE OF MAILING <br />I hereby certify that on this 5'nl day of May, 1997, I mailed <br />a true and correct copy of the foregoing OBJECTION TO BTIPIILATION <br />AND JOINT MOTION TO SETTLE ADVERBARY PROCEEDING AND REQIIEBT FOR <br />HEARING by placing same in the U.S. mail, first class, postage <br />prepaid, and addressed to the individuals listed on the attached <br />list. <br />FEFR1\2301\PLOG\130009. 057 i~ W'~IY VWJ <br />0299.2301 <br />