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V 3037718244 P03 <br /> r <br /> 4. The Application also earaches an exhibit purportedly setting forth services <br /> provided for or expenditures made for the benefit of the Debtor, the date <br /> performed or paid and the dollar expenditure or dollars paid. However, there is <br /> an absence of any tral documentation or information set forth in or attached to <br /> the Application to support Pitkin's claims. Likewise, there is no apportionment <br /> between work or expenditures performed for the benefit of Pitkin versus the <br /> Debtor. <br /> 5. Moreover, there is no apportionment between the amounts claimed by Pitkin in <br /> this Application and for what has been claimed andlor paid to Pitkin pursuant to <br /> the previous three Motions For Use of Cash CoUateral approved by the Court. <br /> 6. Because of the lack of specific detail and information relating to the work <br /> undertaken and expenditures made by Pitldn on behalf of the Debtor, and bct au= <br /> of the lack of specific apportionment between work done for the benefit of Pitkin <br /> and work done for the benefit of the Debtor, and because of the lack of specific <br /> information relating to claims previously made and perhaps paid through the three <br /> Motions For Use of Cash Collateral, Pitidn has failed to support or justify its <br /> application for an allowance of an administrative claim for the$203,096.21 or for <br /> any dollar amount. <br /> Therefore, for the foregoing reasons CCIA objects to Pitkin's Application For Allowance <br /> of Administrative Claim and hereby requests a hearing on this matter. <br /> Respectfully submitted, <br /> By: <br /> M. Kirk Ludwick, Reg. No, 13627 <br /> Ludwick & Rabun, P.C. <br /> 7450 Past Progress Place, #2 <br /> Englewood, Colorado 50111 <br /> telephone; (303) 771-3363 <br /> facsimile; (303) 771-8244 <br /> 2 <br />