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UNITED STATES BANKRUPTCY COURT FOR THE b. James B. Holden, a shareholder in Holden t�Jessop"
<br /> DISTRICT OF COLORADO was a partner in the law firm of Sherman t Howard
<br /> through September 30, 1991. Sherman t Howard has
<br /> In rat ) connections to several creditors of the Debtor on
<br /> matters unrelated to the hebtor. While he was at
<br /> MID-CONTINENT RESOURCES, INC. ) Came No. 92 11658 PAC Sherman t Howard, Mr. Holden did not personally work on
<br /> behalf of any creditors of the Debtor.
<br /> T.I.N. 36-1475193 ) (Chapter 11) c. While at Sherman t Howard, Mr. Holden and other
<br /> lawyers at that firm represented both the Debtor and
<br /> Debtor. the Debtor's parent corporation, Mid-Continent
<br /> Minerals, Inc., in connection with the renegotiation of
<br /> the Debtor's secured debt. Mr. Holden has not
<br /> NOTICE PURSUANT TO RULE 23 OF represented the parent corporation for several years.
<br /> DEBTOR'S APPLICATION TO EMPLOY BANKRUPTCY Holden t Jessop's fees in this bankruptcy case, to the
<br /> COUNSEL (HOLDEN t JESSOP, P.C.), AND SPECIAL extent allowed by the Court, have been guaranteed by
<br /> i
<br /> COUNSEL (SNERMAN t NOWARD AND DELANEY i BALCOMB, P.C.) Mid-Continent Minerals, Inc. Nonetheless, HoldenJessop has been engaged only by the Debtor, and not by
<br /> Mid-Continent Minerals, Inc., in regard to this case,
<br /> TO ALL PARTIES IN INTEREST; and it expressly is understood that any legal
<br /> representation required in this case by the parent
<br /> NOTICE IS HEREBY GIVEN that Debtor has filed three corporation will be obtained from other counsel.
<br /> applications with this Court to employ bankruptcy counsel and Sherman t Howard
<br /> special counsel. The Applications are summarized below. Full
<br /> copies of the Applications are available for inspection in the In the second'Application, the Debtor seeks
<br /> Office of the Clerk of the U.S. Bankruptcy Court, U.S. Custom authorization to employ Sherman t Howard for special purposes in
<br /> House, Suite 116, 721 Nineteenth Street, Denver, Colorado 80202- connection with the Debtor's bankruptcy case. The firm will
<br /> 2508, or upon request from the undersigned attorney. charge the Debtor reasonable fees and expenses for its services,
<br /> based on the normal hourly rates charged by the members of the
<br /> Holden t firm, with all fees and expenses of the firm subject to review by
<br /> In the first Application, the Debtor seeks this Court in accordance with applicable law.
<br /> authorization to employ Holden t Jessop, P.C. as its bankruptcy The special purposes for which Sherman t Howard is to
<br /> counsel in this case. The firm will charge the Debtor reasonable be employed include the following: (i) advising the Debtor on its
<br /> fees and expenses for its services, based on the normal hourly loan obligations to Sanwa Business Credit Corporation; (ii)
<br /> rates charged by the members of the firm, with all fees and advising the Debtor in negotiations to sell the Debtor's coal
<br /> expenses of the firm subject to review by this Court in mine; and (III) to the extent necessary, advising the Debtor on
<br /> accordance with applicable law. The firm holds a retainer from other specialized areas of law related to the Debtor's case,
<br /> the Debtor with a balance, at the time of the Debtor's bankruptcy including environmental, tax, and labor law.
<br /> filing, in the amount of $39,159.29. The retainer will be
<br /> applied to the firm's post-petition fees only in accordance with The Debtor and Sherman t Howard believe that Sherman t
<br /> orders of the Court. Howard does not represent or hold an interest adverse to the
<br /> The Debtor and Holden t Jessop believe that Holden t Debtor or its bankruptcy estate with respect to the matters on
<br /> Jessop is a disinterested person that does not represent or hold which the firm be employed, and that the firm therefore is
<br /> any interest adverse to the Debtor or its bankruptcy estate, and eligible to represent
<br /> seenn t the Debtor in this case and related
<br /> Proceedings. Nonetheless, the firm discloses the following
<br /> that the firm therefore is eligible to represent the Debtor in
<br /> Fonnections to other parties in the cases
<br /> this case and related proceedings. Nonetheless, the firm
<br /> discloses the following connections to other parties in the cases a. The firm has a long-standing attorney-client
<br /> a. Holden t Jessop is unaware of any connections to relationship with the Debtor. The firm also has
<br /> creditors of the Debtor. represented the Debtor's parent corporation, Mid-
<br /> Continent Minerals, Inc., although it does not
<br /> represent Mid-Continent Minerals, Inc. at this time.
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