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I a . pay all liens of secured creditors against the <br /> equipment; <br /> 2 <br /> b. take responsibility for all cleanup which may <br /> 3 be required of the equipment and the other toxic materials <br /> at the R.V. Circuits facility; <br /> a <br /> c. indemnify and hold the trustee and the debtor' s <br /> 5 estate harmless for any costs and expenses in any way <br /> associated with the cleanup; <br /> 6 <br /> d. pay any permit fees; and <br /> 7 <br /> e . perform all other terms of the proposed sale, <br /> 8 as more specifically set forth on Attachment " A" hereto <br /> which is incorporated by reference herein. <br /> 9 <br /> 5 . Alternatively, if the sale is not approved, then <br /> 10 Movant requests the court to grant his prior motion to <br /> abandon the property of having no value to the estate; said <br /> 11 motion being continued to this same date and time . <br /> 12 6 . At the time of the hearing, Movant will further move <br /> the court for a surcharge order against the secured <br /> 13 creditors , pursuant to 11 U. S.C. Section 506 (c) , recovering <br /> the reasonable, necessary costs and expenses of preserving <br /> 14 and/or disposing of the property for the benefit of the <br /> secured creditors and the debtor' s estate, both as to past <br /> 15 costs and projected future needs of the estate. The costs <br /> sought to be recovered under Section 506 (c) include <br /> 16 attorney' s fees and costs incurred by the trustee, include <br /> the following: <br /> 17 <br /> a . attorney' s fees and costs incurred to date in <br /> 18 the preservation and/or disposition of the assets involved. <br /> 19 <br /> b. anticipated future attorney' s fees and costs , <br /> 20 including the handling of this matter through hearing, the <br /> appointment of an accountant, and possibly other matters . <br /> 21 <br /> c. anticipated future accountant' s fees , including <br /> 22 possibly the preparation of a tax return, and tax advice. <br /> 2.1 d. reasonable compensation for Movant as the <br /> trustee. <br /> 24 e. a reasonable " impound" for taxes . <br /> 25 <br /> 7 . Movant requests that the surcharge order be handled <br /> 26 in the following manner: ADL, the prospective purchaser, has <br /> agreed as part of its prior purchase offer to, among other <br /> 27 things, pay all the secured creditors . Movant requests that <br /> LAW OFFICES ADL first pay the amount which the court fixes as a <br /> OF 28 reasonable surcharge under Section 506 (c) directly to <br /> WAGGONER Movant, for deposit into trust. These would be paid in <br /> 6 LOEFFLER <br /> 313 MCRENRV AVE. installments . Movant will hold the funds and not disburse <br /> MOOESTO,CA 95354 <br /> __ 544 7144 <br />