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AFFIDAVIT OF A DIRECTOR OF <br />WELBORN DUFFORD BROWN & TOOLEY, P.C. <br />SPECIAL LITIGATION AND CORPORATE COUNSEL <br />STATE OF COLORADO <br />CITY AND COUNTY OF DENVER <br />The undersigned, being duly sworn, states as follows: <br />1. I am an attorney and director, shareholder and <br />officer of the law firm of Welborn Dufford Brown & Tooley, P.C. <br />(the "Firm"), which maintains offices for the practice of law <br />at 1700 Broadway, Suite 1700, Denver, Colorado 80290-1701. <br />2. This affidavit is being submitted by me in <br />connection with the retention of the Firm as special litigation <br />and corporate counsel to the Debtors herein to render legal <br />services relating to litigation involving the Debtors and the <br />day-to-day conduct of the business affairs of the Debtors, <br />including assisting the Debtors' insolvency counsel, where <br />appropriate. <br />3. As part of its continuing obligation of disclosure, <br />the following additional connection between the Firm and the <br />creditors of the Debtors, other parties in interest and their <br />attorneys and accountants is provided: <br />a. The Firm has been requested by Fuel Resources <br />Development Co. ("Fuelco"), an affiliate of Public Service <br />Company of Colorado, to render oil and gas title opinions. <br />Public Service Company provides electric service to the Debtors <br />in these cases and is a party in interest in Colorado Public <br />Utilities Commission proceedings in which CF&I Steel <br />Corporation ("CF&I") is also a party. These proceedings <br />include, but are not limited to, the current application of <br />Public Service Company to increase its rates for electric <br />service, and the Firm represents CF&I in those proceedings. <br />The Firm does not represent Public Service Company or any of <br />its affiliates in those cases or in any other matters. CFfiI, <br />Public Service Company and Fuelco have consented to the title <br />opinion work to be undertaken by the Firm, and Fuelco and <br />Public Service Company have agreed that the Firm's work for <br />Fuelco will not preclude the Firm from representing CF&I or any <br />of the other Debtors with respect to any current or future <br />matters involving Public Service Company or any of its <br />subsidiary or affiliated companies. The properties upon which <br />- 3 - <br />