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--~~~ III IIIIIIIIIIIIIIII a <br />999 <br />-~z_~ ~ <br />1r3onds, rJv(att~ecvs.,lr3ond~ ~ ~FayEs <br />A CAMP eONDS <br />ALBERT R. MATTNEWS <br />A. CAMP BONDS. JR. <br />O. D. HAVES <br />AHOmeys at Law <br />444 Court <br />Post Office Box 1906 <br />Muskogee, Oklahoma 74402-1906 <br />Telephone: (918) 683-2911 <br />FAX (91 B) 667-0846 <br />December 12, 1995 <br />ez1=r`~I11F~ <br />JULIET N. BRENNAN <br />FANNE LU YAFFE <br />JAMES H. ABRAMS, JR. <br />JEFF M. BONDS <br />DEC 15 1995 <br />QNIS10^ UI r.,P i G I PiJ (1 UGUhIt) I <br />Daniel I. Hernandez <br />Sr. Environmental Protection Specialist <br />Division of Minerals & Geology <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />VIA FACSIMILE 303-832-8106 <br />Re: Applicant/Violator System "Deny" Recommendation, <br />Rimrock Coal Company, The Rimrock Mine, <br />CDMG Permit C-89-074 <br />Dear Mr. Hernandez: <br />Please be advised that the undersigned represents Richard <br />Randall of Randall and Blake of Colorado in conjunction with <br />certain claims made by the Oklahoma Department of Mines concerning <br />Randall and Blake Okla., Inc. <br />You are correct that we did request a continuance for the <br />hearing that was previously set. The reason for the continuance is <br />the claims by the Oklahoma Department of Mines are more than ten <br />years old. It has been a real problem to get records that are that <br />ancient. <br />I am satisfied that the state's claims are invalid. It is my <br />intention to recom*nend to RBI and Mr. Randall that the state's <br />claims be resisted at all steps along the way, including any <br />necessary appeal to the district court. <br />The hearing scheduled for December 8, 1995, was continued at <br />the request of the Department of Mines for the reason that the <br />hearing examiner's father is terminally ill. It was requested by <br />the state that the hearing be delayed until after funeral <br />arrangements and related matters are concluded. I felt that since <br />this matter has been delayed for over ten years, that another few <br />weeks would not make any difference. So, out of respect for the <br />hearing examiner's father, I agreed to their delay. <br />I'm hopeful that your agency will not take any adverse action <br />towards Randall and Blake, Inc, or Mr. Richard Randall since it is <br />our position that the claims of the State of Oklahoma are <br />