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<br /> HI~'G-Ø:3-"31 FRI 16.3':' ¡;J:DEr~T'J!'~> ¡'IC:,Aì1IE TEL íl!]: 512-225-44131 ",i4"~ 20 <br /> '-' -~ <br /> '(j.~ au... Jv <br /> DENTON. ~foKAMllt & NAVARRO <br /> .. PRO'E:tIlIONJ,i.. ÇORPORATION <br /> ATTORNEYS AND COUNSI!:LORS <br /> 'l'OW£k 1..I.l"t; BI 'l.,..I.)lNG, :lóVITE 1100 LOWEI"L t'. DÉNTON <br /> ¡no IiIO1'1'U W1'. M.;'t'cy'¡¡¡ eTI~¡¡¡{tT Vi'U.I...C'HI M.,þ,tç¡CUUE <br /> ¡';¡,!l.N ,,;";1'()NIO, 'l'~X...1iI18i!OI5.:u()a K1OAk(D(J J'. NAY'AHkO <br /> (~h!) a'¡"1-3j¡4-$ August 9, 1991 (.iaARL&9 H. 9IEUH.'>. <br /> tr',....x (1:I1".IIII!<\o"-"'::' Mr. Mark B. Taylor, City Attorney ~ <br /> 630 E. Hopkins <br /> San Marcos, Texas 78666 <br /> RE: Bankruptcy Case No. 91.10097 <br /> C'.offee Equipment, Inc. a/kla Coffee Excavation Debtors <br /> Adversary Proceeding Against rnle City Of San Marcos In Connection With <br /> Contract Construction Claims <br /> Dear Mr. Taylor: <br /> This letter will acknowledge our wi1lingness to accept engagement as council for the <br /> at), of San Marcos to defend the adversary proc,eeding which has been served upon your <br /> City in connection with the reference,d bankruptcy proceeding. We are prepared to accept <br /> engagement, and to enter an appearance on behalf of the City of San Marcos upon receipt <br /> of your confirmation of City Council approval, in accordance with the terms of this letter. <br /> Mr. McKamie and I have reviewed tht~ materials which were provided to us and have <br /> begun an outline of the steps which will be necessary to represent the City of San Marcos' <br /> interests in this matter. We are evaluating the potential validity of each of the claims <br /> stated therein. It is our initial impression that the claims relating to precipitation of <br /> insolvency or bankruptcy by the Debtor do not appear to be sustainable on the basis of the <br /> other financial conditions and circumstances set forth in the documents which we have <br /> reviewed. This, is of course, a very tentative evaluation, We anticipate that it will be thirty <br /> (30) 10 forty-five. (45) days before a firmer evaluation of the City's position could be <br /> reached, <br /> We would anticipate the need for immedíate conferences with City personnel and <br /> other agents under contI acts to the City (which may include design engineers or project <br /> D18nagers) in order to evaluate the delay and other claims which are asserted by the <br /> Debtor. <br /> Our fee structure for handling matten, of this nature, based upon the experience and <br /> knowledge of firm members in connection with proceedings in the Bankruptcy Court are <br /> as follows. These are the regular rates c11arged by the Partners and other attorneys in the <br /> Finn in connection with matters of this type, <br /> -:If.i7 <br />