Case Doc 61 Filed 02/27/15 Entered 02/27/15 16:58:10 Desc Main Document Page 1 of 5

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1 Document Page 1 of 5 David E. Leta (USB #1937) Andrew V. Hardenbrook (USB # 15371) SNELL & WILMER L.L.P. 15 W. South Temple, Suite 1200 Salt Lake City, UT Telephone: (801) Facsimile: (801) dleta@swlaw.com ahardenbrook@swlaw.com Counsel for Federal Resources Corporation and Camp Bird Colorado, Inc. In re FEDERAL RESOURCES CORPORATION and CAMP BIRD COLORADO, INC., Debtors. IN THE UNITED STATES BANKRUPTCY COURT DISTRICT OF UTAH, CENTRAL DIVISION Jointly Administered under Bankruptcy Case No (Chapter 11) Judge Joel T. Marker THIS DOCUMENT RELATES TO: In re Federal Resources Corporation In re Camp Bird Colorado, Inc. Both Debtors NOTICE OF DEBTORS MOTION FOR USE OF CASH TO PAY POST-PETITION OPERATIONAL EXPENSES PURSUANT TO 11 U.S.C. 363 and NOTICE OF HEARING (Objection Deadline: March 16, 2015) (Hearing Date: March 26, 2015, at 10:00 a.m.) PLEASE TAKE NOTICE that Federal Resources Corporation and Camp Bird Colorado, Inc. (collectively, the Debtors ), debtors and debtors-in-possession in the abovecaptioned bankruptcy case, through counsel, have filed a Motion for Use of Cash to Pay Post- Petition Operational Expenses Pursuant to 11 U.S.C. 363 (the Motion ). The Motion is on file with the Clerk of the Bankruptcy Court at the address stated below, and may be reviewed during regular business hours. Copies also may be obtained by sending a

2 Document Page 2 of 5 written request to David E. Leta by mail to 15 W. South Temple, Suite 1200, Salt Lake City, UT or by to dleta@swlaw.com. YOUR RIGHTS MAY BE AFFECTED. You should read these papers carefully and discuss them with your attorney, if you have one in this bankruptcy case. If you do not have an attorney, you may wish to consult one. Through the Motion, the Debtors respectfully request that the Court enter an order authorizing the Debtors to spend up to $20,000 of their cash on hand to pay post-petition expenses consistent with their budget ( Budget ) attached to the Motion as Exhibit A, which includes post-petition storage and office rent, telephone and internet bills, and payroll. 1 The cash on hand is not subject to a security interests and therefore does not constitute cash collateral under 11 U.S.C. 363(a). If you do not want the Court to grant the relief requested in the Motion, then you or your lawyer must both: (1) on or before March 16, 2015, file with the Bankruptcy Court a written objection to the Motion, explaining your position, at: United States Bankruptcy Court 350 South Main Street, Room 301 Salt Lake City, UT If you mail your objection to the Bankruptcy Court for filing you must mail it early enough so that the Court will receive it on or before March 16, You also must mail a copy to the Debtor s counsel at: and Snell & Wilmer L.L.P. David E. Leta 15 W. South Temple, Suite 1200 Salt Lake City, UT (2) attend the hearing on the Motion, which is set for March 26, 2015 at 10:00 a.m. in Courtroom 341, United States Bankruptcy Court, 350 South Main Street, Salt Lake City, Utah Failure to attend the hearing will be deemed a waiver of your objection. 1 As the Budget is merely a projection of expenses, the Debtors request that they be permitted to exceed the amounts identified in the Budget by fifteen percent (15%) without seeking further order of the Court. 2

3 Document Page 3 of 5 If you or your attorney do not take both of the above-described steps, the Bankruptcy Court may decide that you do not oppose the relief sought in the Motion, and may enter an order granting that relief. In the absence of a timely filed objection, the undersigned counsel may and will ask the Court to strike the hearing enter an order approving the Motion without hearing. DATED: February 27, SNELL & WILMER L.L.P. /s/ David E. Leta David E. Leta (USB # 1937) Counsel for Federal Resources Corporation and Camp Bird Colorado, Inc. 3

4 Document Page 4 of 5 CERTIFICATE OF SERVICE Electronic Service (CM/ECF): I hereby certify that on February 27, 2015, I electronically filed the foregoing NOTICE OF DEBTORS MOTION FOR USE OF CASH TO PAY POST- PETITION OPERATIONAL EXPENSES PURSUANT TO 11 U.S.C. 363 and NOTICE OF HEARING with the United States Bankruptcy Court for the District of Utah using the Court s CM/ECF System. I further certify that the parties of record in this case, as identified below, are listed as registered CM/ECF users and will be served through the CM/ECF system: Christopher D. Bryan cbryan@garfieldhecht.com, rortell@garfieldhecht.com James Vincent Cameron tr Vince.Cameron@usdoj.gov, James.Gee@usdoj.gov;Lindsey.Huston@usdoj.gov;Suzanne.Verhaal@usdoj.gov David Dain David.Dain@usdoj.gov, katherine.tribbett@usdoj.gov Andrew V. Hardenbrook ahardenbrook@swlaw.com, jpollard@swlaw.com;docket_slc@swlaw.com Peter J. Kuhn tr Peter.J.Kuhn@usdoj.gov, James.Gee@usdoj.gov;Lindsey.Huston@usdoj.gov;Suzanne.Verhaal@usdoj.gov David E. Leta dleta@swlaw.com, wkalawaia@swlaw.com John B. Lyman john.lyman@usdoj.gov, Katherine.Tribbett@usdoj.gov John M Macfarlane jmacfarlane@fabianlaw.com, aclark@fabianlaw.com Douglas J. Payne dpayne@fabianlaw.com, hmcewen@fabianlaw.com;smcnett@fabianlaw.com Daniel D. Price daniel.price2@usdoj.gov, emily.goodman@usdoj.gov United States Trustee USTPRegion19.SK.ECF@usdoj.gov Mail Service I further certify that on February 27, 2015, I caused the foregoing document to be sent by first class United States mail, postage fully prepaid, to the following at the addresses set forth below: James P. Murphy Murphy, Armstrong & Felton 701 Millennium Tower 719 Second Avenue Seattle, WA Stor-N-Lock Attn: Don Butterfield 1060 North Beck Street Salt Lake City UT

5 Document Page 5 of 5 The Storage Place Attn: Laurel Lindsay P.O. Box 293 Bountiful UT /s/ Andrew Hardenbrook 5