1992-09-17_GENERAL DOCUMENTS - C1981017

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 9/17/1992
• Doc Name: Chapter reorganization
• From: Department of Law
• To: Winston & Strawn
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

OF C
C876 �`
G of Lolorabo STATE SERVICES BUILDING
Gale A. Norton 1525 Sherman Street-5th Floor
Attorney General DEPARTMENT OF LAW Denver, Colorado 80203
Raymond T. Slaughter OFFICE OF THE ATTORNEY GENERAL Phone [phone]&866-3611
Chief Deputy Attorney General FAX [phone]
Timothy M.Tymkovich September 15, 1992
Solicitor General P
Neil Wolf, Esq. SA°O
Winston & Strawn 199�
J!
35 West Wacker Drive
Suite 4200
Chicago, IL 60601
RE: Mid-Continent Resources, Inc. Chapter 11 Reorganization
Dear Mr. Wolf:
As I have been unable to reach you by phone, I would like to take
this opportunity to present for your consideration several issues
which the Colorado Division of Minerals and Geology ("the Divi-
sion") believes should be addressed by the Division and Sanwa
Business Credit Corporation ("Sanwa") . These issues must be
resolved regardless of whether Mid-Continent Resource's bankrupt-
cy proceeding remains a Chapter 11 reorganization, is converted
to a Chapter 7 liquidation or is ultimately dismissed.
Of immediate concern is the marketing and sale of the rock dust
plant, in which the Division has a security interest, and the as-
sociated lease of the CF&I limestone quarry, which the Division
understands to be subject to Sanwa's security interest. Machin-
ery and Equipment Co. ("M&E") , the equipment liquidator employed
by the debtor, has expressed an interest in marketing the rock
dust plant for sale as a going operation. Inclusion of the
quarry lease in the sale is necessary to maximize the return to
both the Division and Sanwa on their respective security inter-
ests. Prior to any division of sale proceeds it is appropriate
for the Division and Sanwa to agree upon the method of sale of
the rock dust plant and lease and the employment of a sales agent
by the debtor, be that agent M&E or another. M&E claims to have
significant contacts which would expedite the sale of the plant
and lease. However, in exchange for its expertise M&E may demand
a higher than normal sales commission. The Division and Sanwa
should consult on a sales and marketing strategy and provide di-
rection to the debtor with respect to this matter as soon as pos-