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 8:20AM #085 P.06
Other Operating Expenses
14. Pitkin Iron Corporation ("Pitkin Iron" )
historically has provided Resources with a number of support
services. Since the discontinuation of Resource's mining
operations, Pitkin Iron's support services have involved
environmental clean up (other than reclamation) , site
maintenance, preparation of assets for liquidation, and equipment
maintenance.
15. Resources estimates the costs of labor, . insurance,
overhead, vehicle rental, vehicle insurance, fuel and repairs
associated with these support services to be $35,000 per month.
This estimate is based on past requirements (e.g. see Exhibit A,
pp 4-5 which includes Pitkin Iron's June and July billings) and
future projections.
16. Resources seeks cash collateral authorization in
the amount of $245,000 to cover these operating expenses for June
through December 1993.
completion of Portal Sealing
17. The Order approving the First Motion authorized
Resources to expend $50, 000 of cash collateral on portal sealing.
The First Motion noted that the amount requested would permit the
sealing of only a portion of the mime portals. Through August
24, 1993, $6,000 had been expended for this purpose.
18. The Order approving the Second Motion authorized
Resources to expend an additional $250,000 for reclamation
activities.
19. In this Third Motion, Resources requests an
additional $51,500 for portal sealing, for a total of $101,500
allocated to portal sealing in the First Motion and Third Motion.
The amount requested is to be used to fund a contract with RAG
Excavating, Inc. , an entity having no affiliation or relationship
with the Debtor. The contract provides for the complete sealing
of all portals.
20. The $50,000 allocated for portal sealing pursuant
to the First Motion shall be expended prior to any use of the
additional $51,500 requested in this Third Motion.
21. The Order approving the Second Motion ordered that
funds spent for reclamation purposes pursuant to the Second
Motion would be reimbursed from the sale of the Rockdust Plant
which is pledged to secure mine reclamation.
22. Section 6.2.7 of the Debtor's pending Plan
provides for a distribution of $1.5 million to a "Reclamation
Account, " but reduces that amount by all funds authorized for
reclamation activities pursuant to the Second Motion and expended
prior to the Plan's effective date. This reduction is made in
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