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1� <br /> Jr <br /> HOLDEN & JESSOP, PC. <br /> ATTORNEYS AT LAW <br /> n 1 <br /> 303 EAST 171- AVENUE, SUITE 930 <br /> '` ` I°��n!!!✓✓✓"` (� DENVER, COLORADO 80203-1264 <br /> n1 1 fj i1 1/IUUI•, 1�/ A (303) 860-7700 <br /> FACSIMILE. (303) 860-7233 <br /> e�4 <br /> January 18, 1994 <br /> VIA HAND DELIVERY <br /> Cheryl A. Linden <br /> Assistant Attorney General <br /> 1525 Sherman Street, 5th Floor <br /> Denver, Colorado 80203 <br /> Re: Mid-Continent Resources, Inc. ( "Resources" ) ; <br /> revised Chapter 11 plan <br /> Dear Cheryl: <br /> I am enclosing "clean" and "red-lined" versions of <br /> Resources' Second Amended Plan. The red-lined version is <br /> preceded by a brief summary of changes which have been made to <br /> the Plan. <br /> Dean Massey advises that if we wish to distribute <br /> materials to the MLRB in advance of the January meeting, you need <br /> materials by tomorrow. We will not have an outline to you by <br /> then, although I anticipate bringing some materials to the <br /> meeting for distribution there. In the meantime, I request that <br /> copies of the red-lined version of the Second Amended Plan and <br /> this letter be distributed to the Board in advance of the <br /> meeting, since this will be central to our discussion with the <br /> Board. <br /> The revised Plan provides for the full funding of the <br /> current reclamation bond, in the amount of $3 million, subject <br /> only to adjustments for work performed to date and services which <br /> Resources' equipment liquidator is required to perform at no <br /> cost. Sanwa Business Credit Corporation, which holds a senior <br /> lien on all assets other than the rockdust plant, has agreed to <br /> this use of its collateral. The liquidation value in the <br /> bankruptcy estate is sufficient to fully fund the reclamation <br /> bond. <br /> Resources has acceded to the MLRB's demand that we <br /> eliminate the concept of a reclamation "trustee, " and that the <br /> MLRB be given control of the funds made available under the Plan <br /> for reclamation. <br /> With respect to the MLRB's desire to have all funds <br /> needed for reclamation delivered up front, it is impossible to <br />