Laserfiche WebLink
,: ~i ~\ /\ <br />DU(iAN and WRTGHI' E X H I B I T B <br />' AT70RNEYS AT LAW <br />Colorado Heritage fNara - Suite 400 <br />1s0 Fast Ninth SiTeet <br />THOnMS PATRICK DUGAN' Poel Office Box 2746 <br />gl$ Rosite <br />TED C. WAIGHT i Qurango, Coloradq 81702 Post Office Box 129 <br />STEVEN F. BUL415 pagosa Springs, Colorado $1147 <br />'Ala admiiid In A4trm+ +nd New Yark (303) 259-1770 (303) 264-211$ <br />'Nw +dmiiird in A.imu <br />e~ugust 26, 1967 <br />brined Land Reclamation Division <br />Colorado Department of Natural Resources <br />1313 Sherman Street, Room 923 <br />Denver, Colorado 80203 <br />Attn: Peter V. O'Connor <br />Reclamation Specialist <br />Re: Cessation Orders C87-023 and C-87-030 <br />Our File No. 1042 <br />Dear Mr. O'Connor: <br />Pursuant to our conversations of August 25, 1987, i am herewiL•h <br />submitting a statement of the position of Dugan Production <br />Corporation, Flaq-Redfern Oil Company and Claremont Exploration, <br />inc. (Frank Podpechan) with respect to the above referenced <br />cessation orders. by letter dated July 28, 1987, the aforenamed <br />parties requested an opportunity to participate in an informal <br />advisement regarding penalties which may be assessed against La <br />Plata Coal Corporation. The advisement conference was continued <br />and then cancelled by Joe Carpio, of La Plata Coal Corporation, <br />and, 1n connection therewith, the Division has afforded the <br />aforenamed parties this opportunity to address the issues. <br />Dugan Production Corporation, Fiag-Redfern oil Company and <br />Claremont Exploration, Inc. (hereinafter referred to as "plain- <br />tiffs") and Joe Carpio formed a partnership on or about December <br />16, 1986, for the purpose of obtaining coal properties and <br />conducting coal mining operations in La Plata County, Colorado. <br />Carpio represented tc the plaintiffs ceal mining expertise and it <br />was agreed that he would conduct actual mining operations and it <br />was further contemplated that Carpio would form an entity for <br />this purpose. On or about January 28, 1987, La Plata Coal <br />Corporation was formed by Joe Carpio and with reapaCt to which <br />the plaintiffs have no equity interest ea ahareholdYrs, <br />In December of 1986 a letter of understanding was drawn up <br />between the Colorado Mined Land Reclamation Division (NERD) and <br />La Plata Coal Corporation (December 12, 1966) t0 allow La Plata <br />