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LAW OFFICES <br /> 1 OF WAGGONER & LOEFFLER i <br /> 318 McHENRY AVENUE <br /> 2 MODESTO, CALIFORNIA 95354 <br /> P;1, 2: 20 <br /> 3 209-544.7144 <br /> 4 <br /> 5 Attorneys for Trustee <br /> Gary R. Farrar <br /> 6 <br /> 7 <br /> 8 <br /> UNITED STATES BANKRUPTCY COURT <br /> 9 EASTERN DISTRICT OF CALIFORNIA <br /> 10 In re the Matter of : NO. 93-95276 <br /> 11 R.V. CIRCUITS, INC. , MC No . MGL-II <br /> 12 Debtor. Chapter 7 <br /> 13 Date : 6/6/94 <br /> Time : 2 : 00 p.m. <br /> 14 <br /> MOTION TO SELL ASSETS OF ESTATE, <br /> 15 ESTABLISH VALUE OF ASSETS, AND <br /> SURCHARGE SECURED CREDITORS PRO <br /> 16 RATA FOR REASONABLE, NECESSARY <br /> COSTS AND EXPENSES OF PRESERVING <br /> 17 AND/OR DISPOSING OF PROPERTY OF <br /> ESTATE : AND NOTICE OF HEARING <br /> 18 <br /> The motion of Gary R. Farrar respectfully alleges : <br /> 19 <br /> 1 . Movant is the duly qualified and acting trustee in <br /> 20 this case. <br /> 21 2 . The only remaining assets of the estate which have <br /> not been previously abandoned by the trustee consist of <br /> 22 miscellaneous office equipment and manufacturing equipment, <br /> presently located at 916 S . Center St . , Stockton. CA. <br /> 23 Secured creditors against the equipment presently total in <br /> excess of $300 , 000 . 00 . Movant is informed and believe and <br /> 24 thereon allege that the equipment is polluted with toxic <br /> waste, to wit, heavy metals . Movant has received a <br /> 25 preliminary estimate for cleanup costs of approximately <br /> $75, 000 . 00 . <br /> 26 <br /> 3 . Movant asks the court for a court order approving <br /> 27 the sale of the equipment to ADL Circuits , Inc . for the <br /> price of $1 , 000 . 00 cash to the estate, to be paid <br /> 28 immediately upon apprbval of the motion by the court, with <br /> ADL also to do each of the following: <br />