1994-01-18_GENERAL DOCUMENTS - C1981017 (3)

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funds, after all distributions to such class or classes have been completed. 7. Discharge provisions. The discharge provision in the former Plan has been deleted, eliminating any issues about whether a discharge is inconsistent with Section 1141 (d) (3) (B) . The New Plan also deletes a provision purporting to create a non-consensual release of Sanwa by creditors of the Debtor. Creditor Support for New Plan 8. The provisions regarding distributions to unsecured creditors have been negotiated with the Unsecured Creditors ' Committee and the New Plan appears to have the support of the members of the Committee. Those members hold in excess of two- thirds of the general unsecured claims, in amount. The New Plan also appears to have the support of Sanwa, the senior secured creditor. 9. The reclamation provisions in the New Plan are based on discussions with the DMG, but are subject to further review by that agency and by the MLRB. The Debtor has been asked to attend the next scheduled meeting of the MLRB, on January 26 or 27, to discuss the provisions of the New Plan. 10. Certain provisions regarding mine reclamation remain somewhat conceptual in nature. Section 4 .3.4 of the New Plan calls for the distributions to the MLRB to be made in accordance with "a reclamation schedule to be negotiated among the Debtor, the DMG, and the MLRB. " The Debtor met with the DMG on January 18 to discuss the reclamation schedule. There appear to be many points of agreement but there may be some points of disagreement. The Debtor anticipates resolving the details concerning the reclamation schedule over the next six weeks. This should occur concurrently with the bankruptcy confirmation process. Respectfully submitted this 18th day of January, 1994 . HOLDEN & JESSOP, P.C. By: (3��- " J es B. Holden, Reg. No. 9020 303 E 17th Avenue, #930 Denve , Colorado 80203 Telephone: (303) 860-7700 Attorneys for Mid-Continent Resources Inc. -3-