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15. Resources requested that certain of Pitkin's employees be retained from these lay- <br /> offs because they had skills which would be useful in Resources' reclamation and liquidation <br /> activities. <br /> 16. In addition, certain of the former Resources' employees who were carved on the <br /> Pitkin payroll would be useful to Resources' reclamation and liquidation activities, and <br /> Resources requested they be continued. <br /> 17. Further, Resources requested that certain items of equipment and vehicles owned <br /> by Pitkin should not be sold, but rather retained for use by Resources in reclamation and <br /> liquidation activities. Pitkin did withhold equipment and vehicles from sale for the use of <br /> Resources. <br /> 18. Pitkin assisted Resources in carrying out reclamation and liquidation obligations <br /> by providing payroll services, equipment, and making necessary purchases. As previously, the <br /> accounts receivable from Resources to Pitkin was continued as an open receivable, with monthly <br /> charges and payments applied to the outstanding balance. <br /> 19. I submitted monthly invoices to Resources. Based on those invoices, Resources <br /> paid Pitkin for charges accrued through August, 1993, and the basis of the claim presented is <br /> thus for charges from September through June, 1994. <br /> 20. Pitkin employees used for work on Resources' projects were designated by <br /> Resources. Their work on behalf of Resources was directed and supervised by Resources. <br /> 21. In determining the charges for payroll services, I relied on daily time sheets <br /> completed by the employees. Charges to Resources were then based on the allocation of time <br /> worked for Resources. <br /> 22. The time allocation was applied against gross pay, FICA, SUT, FUT, workmen's <br /> compensation, employee insurance, and vacation pay. For a salaried employee, the monthly <br /> salary was divided by total cumulative hours per month, to determine hourly rate of pay. <br /> 23. Resources was only charged for time spent on Resources' projects. <br /> 24. In preparing bills, I complied monthly summaries for each employee as to date, <br /> tasks performed, hours worked for either Pitkin or Resources. <br /> 25. Section 3.4 of Pitkin's Exhibit A documents monthly payroll charges, itemized <br /> by employee according to the date, hours and work performed, and apportionment of time <br /> between Resources and Pitkin. <br /> 3 <br />