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Maxine Stewart <br /> Page 3 <br /> plan on the basis that the plan will not be feasibly funded. <br /> However , you should know that from what I gathered from a hearing <br /> before the bankruptcy judge earlier this year , such an objection <br /> may not fall on sympathetic ears. Judge Clark is concerned with <br /> the small amount given to unsecured creditors and also with so <br /> much of the liquidation proceeds going toward reclamation of the <br /> mine site. <br /> Lastly, Jim Holden stated he would be willing to attempt to <br /> respond to some of the Board' s concerns such as making the provi- <br /> sion that requires subtraction of a straight $500, 000 for the <br /> benefits received from the M&E contract to state instead that <br /> amounts will be subtracted as M&E performs demolition required by <br /> the reclamation plan. I assume Jim' s willingness to amend the <br /> plan will end should the Board continue to reject the liquidation <br /> plan. <br /> I will call each of you on March 14, 1994, to get your direction <br /> on whether you want a March 15 executive session to either dis- <br /> cuss this matter further or to reconsider your vote to reject the <br /> liquidation plan in light of the possible changes described <br /> above. I will be out of town from late Friday on March 4 until <br /> March 14. Again, the voting on the liquidation plan and any <br /> objection to confirmation must be filed by March 16 . <br /> Sincerely, <br /> FOR THE ATTORNEY GE RAL <br /> 'i <br /> CHERYL A. LINDEN <br /> Assistant Attorney General <br /> Natural Resources Section <br /> ( 303) 866-5117 <br /> CAL:tm <br /> cc: Mike Long, Director <br /> Steve Renner, DMG <br /> Jerry Goad, First Assistant AG <br /> AG Alpha No. NR CL ICABY <br /> AG File No. E9414185.14 <br />