1994-01-18_GENERAL DOCUMENTS - C1981017

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 1/18/1994
• Doc Name: Revised Chapter 11 Plan
• From: Holden & Jessop PC
• To: Assistant Attorney Generals Office
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

HOLDENTT8c EJESSOP, P.C.
AT LAW
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January 18, 1994
VIA HAND DELIVERY
Cheryl A. Linden
Assistant Attorney General
1525 Sherman Street, 5th Floor
Denver, Colorado 80203
Re: Mid-Continent Resources, Inc. ( "Resources" ) ;
revised Chapter 11 plan
Dear Cheryl:
I am enclosing "clean" and "red-lined" versions of
Resources' Second Amended Plan. The red-lined version is
preceded by a brief summary of changes which have been made to
the Plan.
Dean Massey advises that if we wish to distribute
materials to the MLRB in advance of the January meeting, you need
materials by tomorrow. We will not have an outline to you by
then, although I anticipate bringing some materials to the
meeting for distribution there. In the meantime, I request that
copies of the red-lined version of the Second Amended Plan and
this letter be distributed to the Board in advance of the
meeting, since this will be central to our discussion with the
Board.
The revised Plan provides for the full funding of the
current reclamation bond, in the amount of $3 million, subject
only to adjustments for work performed to date and services which
Resources' equipment liquidator is required to perform at no
cost. Sanwa Business Credit Corporation, which holds a senior
lien on all assets other than the rockdust plant, has agreed to
this use of its collateral. The liquidation value in the
bankruptcy estate is sufficient to fully fund the reclamation
bond.
Resources has acceded to the MLRB's demand that we
eliminate the concept of a reclamation "trustee, " and that the
MLRB be given control of the funds made available under the Plan
for reclamation.
With respect to the MLRB's desire to have all funds
needed for reclamation delivered up front, it is impossible to