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connection with its work under the Agreement. Remcor will be <br />reimbursed on a time and materials basis in accordance with <br />Remcor's then current rate schedule. <br />Necessity of Aork to be Performed <br />20. Due to the large dollar amounts, priority, and <br />number of claims filed against the debtor with respect to the <br />Four Sites, it is essential for the debtor to conduct evaluations <br />of the Four Sites in order to have a basis upon which to quantify <br />and estimate its potential environmental liability at such sites <br />and to estimate the value of the claims filed against it, many of <br />which are filed as unliquidated or contingent, and many of which <br />are duplicative. Absent such an evaluation, there would be scant <br />evidentiary basis to aid the Debtor and the Court in making such <br />crucial estimates. <br />21. Furthermore, the Debtor believes that its ability <br />to attract an investor (one possible avenue of reorganization) <br />may be affected by resolution of its potential liability at the <br />Four Sites. <br />22. The Debtor believes that there are no less <br />expensive alternatives to employing Remcor to perform the <br />evaluation of the Four Sites. The Debtor actively sought bids <br />from four entities, other than Remcor, with respect to the <br />evaluations of the Four Sites. Other bids for the same work were <br />submitted at $131,100 and $268,253. Two parties did not respond <br />due to conflicts of interest. <br />11 <br />