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LAW OFFICES the mo f 1tion by the courts with ADL eine to do each of the • ofollowing: a WAGGONER LOEFFLER )1!4<MFNxVAVENUE = a. pay all liens of secured creditors against the 3 Most, TO. .......................................rAL1r Ox NIA 95asflequipment; J 1 209.5++41+A1 D. Cake responsibility for all cleanup which may I A A be required of the equipment and the other toxic materials 5 at the R.V. Circuits facility; s Attorneys for Trustee Gary R. Farrar c. ss for and hold the penes and the debtor's 1 e a esters harmless Lor any costa and expenses n any we i 7 SSOC laced with the cleanup; 7 pay d. a any permit fees; and fl � fl osed sale UNITED STATES BANKRUPTCY COURT ISTRICT OF CALIFORNIA as more specifically set fort9 e. perform all other terms o[ the prop , 9 EASTERN DISTRICT on Attachment 'A' hereto NO. 9]-95276 10 which is incorporated by reference herein. My u1 In re the Metter of: Interpretation Of the ADL letter offer Is that It contains a HC No. MGL-TI U number of contingencies (actions to be done by the landlord. It R.V. CIRCUITS, INC., etc.); I do not know 1f these can be satisfied, or if there 1 Chapter 7 1I !s eg reemen[ on those point: among the parties involved. 12 Debtor. then 1 U 5. Alternatively, if the sole is not approved, Date: 6/6/9a request the court to grant my prior motion to abandon the the estate; aid motion Time: 2:00 P.M. 1+ property of having no value to a u being continued to this same date and time. 1t DECLARATION OF GARY R. FARTRUSTEE. n 6. At the time of the hearing, I will further move the IN SUPPORT OF MOTION SO SELL ASSETS OF 16 court for o surcharge orderSection against the secured creditors, o 1A ESTATE, ESTABLISH VALUE OF ASSETS, pursuant to Il U.S.C. Section 506(c), recovering the i AND SURCHARGE SECURED CREDITORS PRO 17 reasonable, necessary costs and expenses of preserving, of 17 MTA FOR REASONABLE, NECESSARY COSTS disposing of the property for the benefit of Che secured AND EXPENSES OF PRESERVING AND/OR 18 creditors and the debtor'a estate, both as to pe s[ costs and 14 DISPOSING OF PROPERTY OF ESTATE projected future needs of the estate. The costs sough[ to be 19 recovered under Section 506(c) include attorney's fees and 1 testa incurred by and/or projected In the future by the I, GARY R. FARRAR, declare as follows: p trustee, including the following: M a. attorney' fees and costs Incurred to dace 1. I am the duly qualified and acting trustee In this 21 s In [he preservation and/or dlsposltlon of the assets involved. .1 case iz A supplemental declaration will be filed prior to hearing 2. The only remaining assets Of the estate which have with the specifics; not been previously abandoned by the trustee consist of 11 b. anticipated future attorney's fees and costs, n miscelle neons office equipment and manufacturing equipment, Including the handling of this matter through hearing, the presently located at 916 S. Center St., Stockton. CA. 5+ 7+ Secured f creditors against the Informed equipment presently total In appointment of an eccountent, and pose lb ly other matters. excess o[ $]00,000.00. I am Informed end hOlieve toxic and e, Loon ss •, allege that the equl pment is polluted with toxic waste, c. anticipated future accountant' s feet, including v it, heavy metals. I have received a preliminary estimate Y. possibly the preparation of a tax return, and future tax ramifications o[ sole. R. for cleanup costs of approximately $75,000.00. advice on possible tax durin the last 21 d. reasonable compensation for myself as the 77 /. At the suggestion of the tour[, 9 .p,�.. hearing, at this time I ask the court for a court order o a 21 trustee. At this point I have spent approximately flue ( ) Ls approving the as le of the equipment to ADL Circuits, Inc. ...v,.,� The terms of the sale would include the payment of $1,000-00 cash to the estate, to be paid immediately upon approval of �"yorA.ww x•w.,.w �