1992-09-24_GENERAL DOCUMENTS - C1981017

Home Browse Search

s Xt,41j HoLimq 8c Jzssop. P.C. � X ATTOONO"S AT LAW 302 CAST 17To AV[NUC.SUIT[930 OCNVtp, COLORNOO e0$09-11RO4 13071 060.7700 PACSI14116t. 13031 $00•1833 September 22, 1992 RE( Neil Wolf $ Winston t Strawn SEP 2 4 1992 35 West Wacker Drive Chicago, IL 60601 Stephen W. Seifert NER: Fairfield and woods, P.C. 1700 Lincoln Street, Suite 2400 Denver, Colorado 60203 Frank R. Johnson Assistant Attorney General 1525 Sherman Street, 5th Floor Denver Colorado 60203 Re: Mid-Continent Resources ( "Resources") ; liquidation plan Gentlemen: Z wrote two of you (Neil and Steve) on July 28 to outline the equipment sale program which since has been approved by Judge Clark. That letter concluded with an expression of my desire to see a continuation of negotiations among the interested parties in this case regarding the distribution of liquidation proceeds. The permanent cessation of mine activities and the revocation of Resources ' mining permit has caused reclamation claims to ripen and has created three distinct groups of creditors- ,in this case: Sanwa,' the Colorado Mined Land Reclamation Division (the "Division") , and the general unsecured creditors, represented by the Creditors' Committee. I therefore address this letter to the representatives to these three camps. During the pendency of the Geneva negotiations, Judge Clark made it fairly clear that she was not inclined to leave the case in Chapter 11 if all we were doing was liquidating Sanwa's collateral and turning the proceeds over to Sanwa, since Sanwa presumably could obtain the same result by foreclosing its liens outside of bankruptcy. After the collapse of the Geneva negotiations, Judge Clark directed me to file a status report Z'd dOSS3f 18 H3TIOH Wd00:60 26. 22 d3S