1993-11-26_GENERAL DOCUMENTS - C1981017 ‎(2)‎

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 11/26/1993
• Doc Name: Case No. 11658 Notice of Pursuant to Local Bankruptcy Rule 202 of Application to Emplo Special
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

of the Debtor. All funds currently in the possession of the
Debtor are cash collateral. Pursuant to 11 U.S.C. § 363, the
Debtor seeks authorization to use $20,000 of cash collateral to
pay such a retainer.
17. Notwithstanding the payment of a retainer, the
fees and expenses of Parcel Mauro, including but not limited to
any draws on the retainer, shall be subject to prior review and
authorization by this Court in accordance with applicable law.
18. The firm has advised the Debtor that it will
charge the Debtor for fees and expenses based on the normal
hourly rates charged by the members and employees of the firm.
The hourly rate of the primary lawyer in charge of this matter,
Dean Massey, currently is $185 per hour.
19. To the best of the Debtor's knowledge, Parcel
Mauro holds no interest adverse to the Debtor or its bankruptcy
estate with respect to the matter on which the firm is to be
employed. Attached hereto is the verified statement of Dean
Massey, pursuant to Bankruptcy Rule 2014, setting forth the
firm's connections with the Debtor, creditors, any other party in
interest, their respective attorneys and accountants, the United
States Trustee, or any person employed in the office of the
United States Trustee.
20. A copy of this Motion together with a L.B.R. 202
Notice is being served on the United States Trustee, the Official
Committee of Unsecured Creditors, all persons who have requested
notice, and any persons who have or may claim an interest in the
Debtor's cash collateral.
WHEREFORE, pursuant to 11 U.S.C. §S 327(e) and
1107, the Debtor requests that it be authorized (i) to employ
Parcel Mauro Hultin & Spaanstra, P.C. as special counsel in the
above - captioned case and related proceedings with respect to the
matters described above, and (ii) to provide a retainer of
$20,000 in connection with such employment.
Respectfully submitted this 0 of November, 1993.
HOLDEN & JESSOP, P.C.
_-James B. Holden T9020
0 East 17th Avenue, €930
Denver, Colorado 80203
Telephone: [phone]
Attorneys for Mid- Continent Resources,
Inc.
-4-