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ered by prior cash collateral motions. <br /> 4 . The first two Motions for Authorization to Use Cash <br /> Collateral specified certain monthly expenses of the debtor which <br /> included certain tasks done by Pitkin. The third motion request- <br /> ed $245, 000 for tasks done or to be done by Pitkin for the period <br /> of June 1993 to December 1993. <br /> 5. It is uncertain how much Pitkin has been paid pursuant <br /> to the cash collateral motions and for which performed tasks. It <br /> is also uncertain whether there is an overlap between the amount <br /> Pitkin is now requesting and the amounts covered in the prior <br /> cash collateral motions. <br /> 6. Moreover, the document attached to Pitkin's present re- <br /> quest does not specify the particular work for which Pitkin is <br /> requesting payment. For example, there are numerous references <br /> to "payroll charges, " but there is no explanation of what these <br /> charges include or cover. In addition, there is no documentation <br /> to show apportionment between the work or expenditures performed <br /> for the benefit of the debtor versus the work or expenditures <br /> performed for the benefit of Pitkin. <br /> 7 . Pitkin has failed to support or justify its application <br /> for allowance of an administrative claim in the amount of <br /> $203 , 096. 21. <br /> For the foregoing reasons, the Colorado Division of Min- <br /> erals and Geology objects to Pitkin's Application for Allowance <br /> of Administrative Claim, and requests a hearing on this matter. <br /> GALE A. NORTON <br /> Attorney General <br /> STEPHEN K. ERKENBRACK <br /> Chief Deputy Attorney General <br /> TIMOTHY M. TYMKOVICH <br /> Solicitor General <br /> PATRICIA S. BANGERT <br /> Deputy Attorney General <br /> -2- <br />