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1 the motion by the court, with ADL also to do each of the <br /> following: <br /> 2 <br /> a . pay all liens of secured creditors against the <br /> 3 equipment; <br /> 4 b. take responsibility for all cleanup which may <br /> be required of the equipment and the other toxic materials <br /> 5 at the R.V. Circuits facility; <br /> 6 c. indemnify and hold the trustee and the debtor' s <br /> estate harmless for any costs and expenses in any way <br /> 7 associated with the cleanup; <br /> 8 d. pay any permit fees; and <br /> q e. perform all other terms of the proposed sale, <br /> as more specifically set forth on Attachment 'A" hereto <br /> 10 which is incorporated by reference herein. My <br /> interpretation of the ADL letter offer is that it contains a <br /> 11 number of contingencies (actions to be done by the landlord, <br /> etc. ) ; I do not know if these can be satisfied, or if there <br /> 12 is agreement on those points among the parties involved. <br /> 13 5 . Alternatively, if the sale is not approved, then I <br /> request the court to grant my prior motion to abandon the <br /> 14 property of having no value to the estate; said motion <br /> being continued to this same date and time. <br /> 15 <br /> 6 . At the time of the hearing, I will further move the <br /> 16 court for a surcharge order against the secured creditors, <br /> pursuant to 11 U.S.C. Section 506 (c) , recovering the <br /> 17 reasonable, necessary costs and expenses of preserving, or <br /> disposing of the property for the benefit of the secured <br /> 18 creditors and the debtor' s estate, both as to past costs and <br /> projected future needs of the estate. The costs sought to be <br /> 19 recovered under Section 506 (c) include attorney' s fees and <br /> costs incurred by and/or projected in the future by the <br /> 20 trustee, including the following: <br /> 21 a. attorney' s fees and costs incurred to date in <br /> the preservation and/or disposition of the assets involved. <br /> 22 A supplemental declaration will be filed prior to hearing <br /> with the specifics; <br /> 23 b. anticipated future attorney' s fees and costs, <br /> 24 including the handling of this matter through hearing, the <br /> appointment of an accountant, and possibly other matters . <br /> 25 <br /> c. anticipated future accountant' s fees, including <br /> 26 possibly the preparation of a tax return, and future tax <br /> advice on possible tax ramifications of sale. <br /> 27 <br /> LAW OFF,�S d. reasonable compensation for myself as the <br /> OF 28 trustee . At this point I have spent approximately five (5) <br /> WAGGONER <br /> 8 LOEFFL R <br /> JIB MCHENW AVE. 2 <br /> MOOESTO,CA 95 <br /> 2J&544'l141 <br />