GENERAL43249

• Permit No: M1997054
• IBM Index Class Name: General Documents
• Doc Date: 4/23/2004
• Doc Name: Colorado Materials Holding Corporation
• From: Robinson Waters & ODorisio
• To: DMG
• Media Type: D
• Archive: No

~l'1'7~ODU ©~ ~ LAW OFFICES OF
A Professional Corporation
ANTHONY L. LEFFERT
aleffert(a7rwolaw.com
C~
Apri122, 2004. RECE11/~ ; ~~
APR p 3 ZOpq L/
/Unsecured Creditors Dniaion o(Mi1efal$ end ceole
Colorado Materials Holding Corporation er
Agile Stone Systems, Inc.
Re:~lorado Materials Holding Corporation, Case No. 03-16688-ABC
Agile Stone Systems, Inc., Case No. 03-16692-ABC
Dear Sirs:
Please be advised that I am legal counsel for the Unsecured Creditors' Committee
of the Colorado Materials Holding Corporation ("COMAT"). The Bankruptcy Court has
approved my representation of the Unsecured Creditors' Committee.
Recently you have received an Amended Disclosure Statement and an Amended
Joint Plan of Reorganization dated January 27, 2004 from the attorneys for COMAT. In
this Amended Disclosure Statement and Amended Joint Plan of Reorganization, the
Debtor seeks your vote to confirm their Plan of Reorganization. This letter is to advise
you that the Unsecured Creditors' Committee is opposing confirmation of the Amended
Plan. Moreover, the members of the Unsecured Creditors' Committee would urge you to
vote against confirmation of the Plan of Reorganization for the reasons set forth in this
letter.
On Apri129, 2003, COMAT, by and through its President; Randall Case, prepazed
and filed BanlQUptcy Schedules for the Chapter 11 Reorganization. As part of the
Bankruptcy Schedules filed at that time, COMAT listed assets of $71,314,669.65. The
liabilities listed for COMAT were $16,748,160.14. The Unsecured Creditors' Committee
and counsel were told by various parties that there were more than sufficient assets which
could be reorganized in a manner that all unsecured creditors would be paid in full. The
Amended Plan proposed by COMAT, however, provides for the possible payment of
approximately eleven cents on the dollaz for unsecured creditors. The Committee does
not believe that there has been adequate disclosure made by the Debtor to explain why
under the proposed Amended Plan only $2,605,318.00 will be paid by the secured lender
for the assets of COMAT and Agile Stone Systems, Inc. when the net asset value
reflected in the Debtor's schedules filed less than one yeaz ago was $54,566,509.00.
RHO
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#98432 vl - It all unsecured creditors