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FAiRFIELD AND WOODS, PC. <br /> ATTORNEYS kND COUNSELORS AT LAW <br /> James Holden <br /> July 30, 1993 <br /> Page 5 <br /> Section 6 . 5 -- It should be made clear that if there has been <br /> any cost so far associated with preservation and/or assumption of <br /> the Mid-Continent Quarry lease, and if there is any such cost in <br /> the future, all of those costs are to be paid or reimbursed by the <br /> Reclamation Trust . Also, even though the M&E Contract is going to <br /> the Creditors' Trust, the Reclamation Trust is getting $1 . 5 million <br /> off the top from sales of assets, including equipment sales . There <br /> have been considerable costs associated with the M&E Contract, and <br /> if arbitration and other matters proceed there will be more costs . <br /> As now drafted, all of those costs are borne by the Creditors' <br /> Trust even though the Reclamation Trust gets cash off the top. The <br /> Reclamation Trust should be charged some share of these costs . <br /> Section 6 . 6 -- CCIA has said that it will vote for the Plan <br /> only if the Debtor removes its objection to the CCIA claims . Some <br /> provision therefore needs to be made so stating. Also, do you <br /> believe that 30 days after the Effective Date is enough time to <br /> prepare objections to claims? <br /> Section 7 . 1 -- The phrase "such holder' s claims" in the sixth <br /> line from the bottom refers back to claims by Class 9 creditors . <br /> The use of that phrase in this place, however, is meant to refer to <br /> the claims of Sanwa, Minerals, and so forth. This needs to be <br /> clarified. <br /> Section 7 . 6 -- Please add a section preserving for the <br /> Creditors' Trust all avoiding actions . <br /> Section 8 . 1 -- I think that the lead-in phrase needs to be re- <br /> written in order to make sense . <br /> Disclosure Statement : <br /> First, a number of the comments from the Plan will have to be <br /> carried over to their appropriate references in the Disclosure <br /> Statement as well . <br /> Second, I would suggest on page ii setting the typeface for <br /> the sentence about the Debtor' s recommendation in bold, along with <br /> the last paragraph about returning ballots . <br /> Please add page references in the Table of Contents . <br /> Page 1, Paragraph B -- the words "the next" are duplicated in <br /> the third line down. <br />