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15 . Resources ' real and personal property which has <br /> been converted to cash collateral is subject to the following <br /> liens : <br /> a . The State of Colorado and its political <br /> subdivisions , Pitkin County, Garfield County, and <br /> Gunnison County, hold statutory tax liens , by operation <br /> of C.R. S . §39-1-107 , on all taxable real and personal <br /> property of Resources , to secure the payment of real <br /> and personal property taxes . Resources anticipates <br /> that the liquidation of its real and personal property <br /> will generate ample proceeds to satisfy these taxes , <br /> and Resources therefore believes that the State and its <br /> subdivisions are adequately protected notwithstanding <br /> the use of cash collateral requested above . <br /> b. Sanwa Business Credit Corporation ( "Sanwa" ) holds <br /> consensual liens on all personal and real property of <br /> Resources located in the State of Colorado, <br /> specifically including real property in Pitkin County <br /> and equipment wherever located. These consensual liens <br /> have priority over all other liens, except statutory <br /> liens for taxes, a lien of the Mined Land Reclamation <br /> Division on a rockdust plant which has not been sold, <br /> and a few purchase money security interests on <br /> equipment which do not include any equipment sold to <br /> date ( specifically including equipment secured by <br /> purchase money liens held by Caterpillar Financial <br /> Corporation) . Sanwa's liens secure claims against <br /> Resources in the approximate amount of $29 , 000 , 000 . <br /> Resources acknowledges that the funds which Resources <br /> proposes to spend are, in fact, cash collateral of <br /> Sanwa and that there are no funds available to <br /> Resources that are not Sanwa ' s cash collateral. Sanwa <br /> is being served with a copv of this Second Motion and <br /> the accompanying notice, and in the absence of timely <br /> objection consent to the use of cash collateral may be <br /> presumed. <br /> C. Consensual equipment liens held by Public Service <br /> Company of Colorado and Colorado Compensation Insurance <br /> Authcrity are junior to the liens held by Sanwa, so the <br /> Debtor submits that the liens are valueless and <br /> therefore that no adequate protection is required. <br /> Further, Resources believes that none of the funds <br /> available to Resources is cash collateral of these <br /> creditors and, therefore, their consent is not <br /> necessary. Nonetheless, a copy of this motion and the <br /> accompanying notice are being served on these creditors <br /> and in the absence of timely objection consent to the <br /> use of cash collateral may be presumed. <br /> -6- <br />