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LAW OFFICE! ,.1 or 1 a. pay all Ilene of secured creditors against the � WAGGONER a LOEFFLER —., equipment; V x 31!MaNENAY^VENUE 1 MOOESx O.CALIFORNIA 9l1SV :y, b. take responslblllty [or all cleanup which may ....................................... xO9s.9n A, 7 be required of the equipment and the other toxic materials at the R.V. Clrculta facility; IACa i AI I CALTI� , 11 c. Indemnify and hold the trustee and the debtor' s 5 Attorneys for Trustee PR O '' t� (` ' �'r f estate harmless for any costs and expenses in any way � Gary R. Farrar associated with the cleanup; .'4 MARY 15 PM Il 56 ^ d. pay any permit fees; and 1 e. perform all other terms of the proposed sale, ^ A as more specifically set forth on Attachment 'A' hereto UNITED STATES BANKRUPTCY COURT which la Incorporated by reference herein. r o EASTERN DISTRICT OF CALIFORNIA s 5. Alternatively, 1f the Gale is not approved, then In In re the Matter o[: NO. 9)-95276 1p Movant requests the court to grant his prior motion to abandon the property Of having no value to the estate; said Il R.V. CIRCUITS, INC., MC No. MGL-Il 11 mo cion being continued to this same date and time. 6. At the time of the hearing, Movant will further move 12 Debtor. Chapter 7 17 / the court for a surcharge order against the secured n Daae: 6/6/91 11 creditors, pursuant to 11 U.S.C. Section 506(c), recovering Time: 2:00 p.m. the reasonable, necessary costs and expenses of of thev ng 1 H and/or disposing of the property for the bene[![ of the MOTION TO SELL ASSETS OF ESTATE, secured creditors and the debtor' s estate, both as to past 1, ESTABLISH VALUE OF ASSETS, AND 1, costs and projected future needs of the estate. The costs SURCIIARGF. SECURED CREDITORS PRO sought to be recovered under Section 506(c) include i p. RATA FOR REASONABLE., NECESSARY u. attorney' s fees and costs incurred by the trustee, include AN COSTS AND EXPENSES OF PRESERVING the following: Il AND/OR DISPOSING OF PROPERTY OF 11 . la a. attorney's fees and tae incurred to date to I ESTATEN NA PTICE FMEARINC the preservationand/or disposition Of the assets Involved. The motion of Gary R. Farrar respectfully alleges: 1" Po 1. Movant is the duly qualified and acting trustee in b. anticipated future at Lorney's fees and costs, 11 this case. p appointment the handling of this matter possibly of hearing, the appolntmen[ of an accountant, and coos lb ly ether matters. I ±1 2. The only remaining assets of the estate which have n c, anticipated future accountant' s fees, including not been previously abandoned by the trustee consist of miscellaneous office equipmnnt and manufacturing equllxnenL, x1 possibly the preparation o[ a tax return, end sax advice. presently located at 916 S. Center St., Stockton. CA. d, reasonable compensation for Movant as the a Secured creditors against the equipment presently total In 11 excess of (700,000.00. Movant Is Informed and believe and trustee. ±+ thereon allege that the equipment is polluted with toxic N e. a reasonable 'impound' for taxes. waste, to it, heavy metals. Movant has redelved a 2t. 7, Movant requests that the surcharge order be handled preliminary estimate for cleanup costs oflapproxlmately 25 $15,000.00. the prospective urchaser, has ±A ±^ in the following manner: ADL, s p pamon other J. Movant asks the court for a court order approving agreed as part o[ Its prior coeditor otter to, g p the sale of the equipment to AOL Circuits, Inc. for the xl things, pay all the scour rd ch the co. Movant requests that price of [1,000.00 cash to the estate, to be paid o,�FF ADL first pay the amount which the court [lies as a ±s immediately upon approval of the motion by the court, with �,L.`�lnP la reasonable surcharge under Section 506(c) directly [o ADI. also co do each of the following: F w.e� Movant, for deposit Into trust. These would be paid In Installments. Movant. will hold the funds and not disburse vm+wu mw