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e ddys in working on this case, p Finally, I need some way to continue to have some pe this one as act of the case i 9• Y, only. I eek for reasonable compensation in accordance with control over the sl deptua th a ![ ADL defaults,a. I will a discuss the statutory percentages for trustee' s compensation (see 1 this Issue In more depth at the hearing,nq, end may file a information concerning valuation, below) or such other supplemental declaration prior to heeri ng on cels lanae. reasonable basis as the court may decide. 1 1 declare under penalty of perjury that the foregoing e. a reasonable 'lmpountl' for possible Income Is true and correct, except as to those matters stated on taxes resulting from the aele. [ am consulting with Paul Information and belle[, and re to llose tetters, I am 1 pulnn, CPA on this subject and I anticipate will have more f informed and believe and thereon allege that they ate true specifics for the court, in the form of a declaration, prior and correct. Executed in Modesto, C' on f/ay 1994. 6 Co hearing. The question of potential income tax liability a 'y //i^, deals with Information that I do not yet have, such as the .Trustee' —5 1 basis of the various assets, how much depreciation has been 7 taken, etc. This may be as much as $100,000.00, although I N simply do not know at this point. a v f. a further impound so that I may retain Steve B. v Mueller of Omni Environmental Group as my expert to assist J\ to me overseeing rseeing the ADL cleanup work. In � u 7. I request that the surcharge order be handled In the a following manner: I request Choc ADL furs[ pay the amount u welch the court flees as o reasonable surcharge under II Section 50he directly to me, for deposit loco my trust 1, account. These would be paid in Installments. I will hold p the funds and not disburse them until the close of the case, _ i, after court approval of the various item.. Any eemaining 14 amount not used up will be handled In the normal manner when Is the estate Is wound up. ADL would then pay the secured with if creditors the remainder of the amount of their claims, n, this amount deducted pro rata from the secured cradltors' le claims. In effect, this would result In the secured n creditors' being surcharged and paying these amounts, rather 11 than ADL. tl ifl S. I also ask the court to value the equipment involved Iv In this motion, for purposes of the court's setting the Iv appropriate surcharge amount under Section 506(c). It is V difficult to value the equipment. The debtor' s Schedule B p does not give a value ('unknown'--Item 27). however, I suggest that one method of doing so is to evaluate the ADL ii offer, as a means of establishing 'fair market value.' ADL has offered: 22 a. $1,000.00 cash: and 71 ■ t1 b. to take care of the cleanup. The preliminary 27 estimate from Steve Mueller of Omni was $74,555.00; and - c. to pay all the secured creditors. i ask the � court to take judicial notice of Schedule D (Creditors 7n Molding Secured Claims) for this limited purpose. It appears that the secured claims are In the neighborhood of 27 - $400,000.00. U.o.us Yn...............e 3