1993-10-15_GENERAL DOCUMENTS - C1981017

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 10/15/1993
• Doc Name: 3rd motion for authorization to use cash collateral
• From: US District Court
• To: Mid-Continent Resources, Inc.
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

FROM:natural TO=DMG OCT 15, 1993 8:19AM #085 P.05
6. On February 25, 1993, Resources filed a Motion for
Authorization to Use Cash Collateral (the "First Motion" ) which,
as amended, was approved by Order of this Court dated March 22,
1993. On May 17, 1993, Resources filed a Second Motion for
Authorization to Use Cash Collateral (the "Second Motion" ) which,
as amended, was approved by Order of this Court dated June 9,
1993. Pursuant to these Orders, Resources was authorized to use
cash collateral for the purposes and in the amounts as set forth
in the Motions, as amended.
7. A summary of Resources cash position as of August
23, 1993, is attached hereto as Exhibit A, and a recap of
Resources' use of cash collateral through August 23, 1993 is
attached hereto as Exhibit B.
B. Resources has filed a First Amended Plan of
Liquidation (the "Plan" ) on October 1, 1993, which allocates
liquidation proceeds among secured creditors, unsecured
creditors, and environmental claimants.
9. Pending confirmation of the Plan, Resources has a
continuing need to expend funds for purposes of administering its
estate, as set forth below. Resources requests authorization to
use cash collateral for those purposes.
CASH COLLATERAL REQUEST
10. in this Third Motion, Resources seeks to obtain
authorization to use cash collateral for (i) general and
administrative expenses for June through December 1993, (ii)
other operating expenses for June through December 1993; (111)
completion of mine portal sealing, (iv) pond cleaning, (v) flume
repair, (vi) PCB removal, (vii) real estate taxes, and (viii)
allowed legal fees and expenses. These proposed expenditures are
described in more detail below, by category.
General and Administrative Expenses
11. Resources has incurred, and continues to incur,
ongoing general and administrative (G&A) expenses for utilities,
insurance, permits, and contract labor (which includes no
compensation to any officers or directors of Resources) . The
monthly average for G&A expenses is estimated at $7,500; certain
expenses which were treated as monthly operating expenses under
the Second Motion have now been reallocated to other categories.
12. An estimate of G&A expenses is attached hereto as
Exhibit C. The expenses shown on Exhibit C include $2,000 per
month for special counsel, Ed Mulhall of Delaney & Balcomb, P.C. ;
this is discussed under the category "Legal Expenses" below, and
thus has been deducted from the "G&A" category.
13. Resources seeks cash collateral authorization in
the amount of $52,500, to cover G&A expenses for June through
December 1993.
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