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 8:21AM #085 P.09
38. Funds spent to redeem the Rockdust Plant from tax
sale are subject to the provisions of Paragraph 23 above. Since
the Rockdust Plant is combined with other property under Tax
Schedule No. 111391, it will be necessary to allocate a portion
of the cost of redeeming all property under that Schedule.
Resources proposes to allocate 40% of the cost of redeeming under
that Schedule to the Rockdust Plant. This represents the
approximate percentage which the value of the Rockdust Plant has
to all property under the Schedule. This would allocate
approximately $26,400 of the redemption cost against the Rockdust
Plant.
Legal fees and expenses
39. Under the pending Plan, all allowed administrative
expenses, including the allowed fees and expenses of counsel for
the Debtor and the Creditors' Committee, must be paid as a
condition to confirmation. There are several attorneys whose
fees and expenses have been allowed or who have applications for
allowance pending. Other attorneys are performing ongoing
services but anticipate submitting fee applications prior to
confirmation of the Plan. The Debtor seeks authorization to pay
interim or final fees and expenses to these attorneys, to the
extent such fees and expenses are allowed by the Court, prior to
confirmation of the Plan.
40. Sherman & Howard was employed as special counsel
for the Debtor in matters pertaining to the attempted sale of the
Debtor's mine to Geneva Steel Corporation. Following the
termination of these sale negotiations, the firm filed its final
fee application. On March 15, 1993, the Court allowed and
authorized the payment of $45,407.50 of fees and $2,234.55 of
expenses to Sherman & Howard. The Debtor seeks authorization to
pay these fees and expenses in full.
41. Holden & Jessop, P.C. is employed as the Debtor's
bankruptcy counsel. The firm has filed a Second Application for
Interim Fees and Reimbursement of Expenses, pertaining to the
period of June 1, 1992 through September 30, 1993, seeking
authorization to be paid 75% of its allowed interim fees and 100%
of its allowed interim expenses, which would require the Debtor
to pay $43, 142.19 to the firm. The Debtor seeks authorization to
pay interim fees and expenses as allowed by the Court.
42. Delaney and Balcomb, P.C. , is employed as special
counsel to the Debtor. The firm has two interim applications
pending seeking fees and expenses of $36,420.75, of which $2,697
have previously not been paid. The Debtor seeks authorization to
pay up to $2,697 as an interim fee.
43. Fairfield and Woods, P.C. , counsel for the
Creditors' Committee, has accrued fees during the period of
August 1, 1992 through September 30, 1993 in the approximate
amount of $35,000. The Debtor seeks authorization to pay up to
75% of that amount, or $26,250, as an interim fee.
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