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UNITED STAVES BANKRUPTCY COURT FOR THE <br /> DISTRICT OF COLORADO <br /> In re: ) <br /> MID-CONTINENT RESOURCES, INC. ) Case NO. 92 11658 PAC <br /> (Chapter 11) <br /> T. I.N. 36-1475193 ) Motion Control No. P-1 <br /> Debtor. ) <br /> APPLICATION-OF PITKIN IRON CORPORATION FOR <br /> ALLOWANCE OF ADMINISTRATIVE-CLAIM <br /> Pitkin Iron Corporation (PITKIN) applies for allowance of <br /> administrative claim for post petition contract services performed, <br /> machines rented, supplies purchased, personnel provided, and <br /> related items by Pitkin for the use and benefit of Debtor based <br /> upon invoices approved by Debtor, copies of which are attached <br /> hereto as Exhibit A which cover the period from August 1, 1992 <br /> through June 30, 1994. The claim is for $203,096.21. <br /> In support of this Application, Pitkin shows: <br /> 1. Pitkin refers to and adopts by reference Motions <br /> filed by Debtor for use of cash collateral, approved by Order of <br /> the Court as follows: <br /> First Motion, Filed February 25, 1993, approved March 22, <br /> 1993. <br /> Second Motion, Filed May 17, 1993, approved June 9, 1993. <br /> Third Motion, Filed October 19, 1993, approved November 17, <br /> 1993. <br /> 2. The above expenditures materially assisted Debtor in <br /> managing and preserving the bankrupt estate; in clean up and <br /> preparation for sale of personal property and land; in moving <br /> machinery and equipment to a secure place to avoid theft and loss; <br /> in performing major steps toward reclamation of the mine property; <br /> and bringing the mining property into compliance under the SMCRA <br /> requirements imposed by the State of Colorado and Office of Surface <br /> Mining; in managing, and taking care of disposition of hazardous <br /> waste, primarily PBC contaminated transformers; in sampling, <br /> analysis and otherwise complying with regulations of the EPA; <br /> Colorado Department of Health, and other agencies; and road and <br />