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Mr. Midnd Baday <br />Dicitin ajMurraG and G~ <br />Janumy 18, 1999 <br />Page 1 <br />Comment 3 - In the list of o~ers and dirarors tlaxt had bait sulnritigl for dx Interior Holdings Corprrr-atian, <br />Frank M. Cnstora a end data[ as Assist~au Tm~csumr an 1/31/98. Hourcer, yr A VS, he is not end dcel If <br />Frank M. Castors rro ~ holds that positun for tlxrt cvrrJrmy, please state thu fact and the date grtemtntatitn on <br />offuial mrtpvey letterlxad &ratcre A VS u lake[ for dx Interior Holdings Corlpratun, the State tint not revise arty <br />envies for this ompmry. 7herefom, place seal tlx tentrnmtiat v fimt>atrc~ to OSM~AVS so thrtt they um uptfate <br />A VS. <br />Our database is correct and Frank M. Castors was terminated on 1/31/98. The appropriate <br />termination information on official company letterhead had been sent to OSM-AVS previously <br />and they have since updated their database. For the Division's sake, it should be noted that on <br />page four of the listing of Officers and Directors for Peabody Holding Company, Inc., that Frank <br />M. Castors was also end dated on 1/31/98. <br />Comment 4 - In AVS and in the list of offrms and dnawrs had lzror sulnv'ttal for thr Pealzrly Holding <br />CmzFmry, Gmrge J. Hohtuy is era' data[ on 6/1 S/98 for tIx pusitiart of [/im Presideu, hut, in a separate entry, i< <br />also b~rrtnatg date? on 6/15/98, with no end due, for Vice Presulertt Please explain Also, please p,wide offuial <br />mnftmtakcvt on mrtjtmy letterfxad of the tennntatiat and dx temtirtatim date so dwt A VS cart lx t yxlataL <br />On the 06/15/98 date, George M. Holway was given the additional titles of Chief Financial <br />Officer and Director for Peabody Holding Company, Inc. Because of the complexiry, number of <br />different officers and directors, etc. for each of our companies, and numerous changes, that one <br />pazticulaz envy was end dated and then regrouped with his other two tides. With the submittal of <br />this response package, you will see that for the revised listing he has since been temvnaced as a <br />Director on 10/ 13/98, but has retained his other two titles. <br />Comment 5 - In tlx list of offia~rs and dirzturis that had bit subhvttal for the Pealttly Holding Cartlmry, <br />7lxnws S. Hdtmt rs end date[ at 6/19/98, btu rn A VS tlx end date is 6/16/98. Please mtmale this differ <br />Also, please pnicide official ¢nfim~ivt on corgmry letterlxad of tlx tenrtiruuiaz and Jx tennnurtiot:date. <br />Thomas S. Hilton was end dated on 06/19/98 and the 06/16/98 shown in OSM-AVS was a <br />typographical error on their part. They have since made the correction to their rystem. <br />Comment 6 - In the list of offrcers and dinttors that had best sttbnittal for dx Pea&>ly Holding Cm~mry, L~rek <br />C BaJxan is erul dotal at 5/11 /98. Horeerx , vt A VS, tlx erul date u 5/11/98. Please ratauile this differot~ <br />and prorAde a nuisal subrtitral page, if appropriate. <br />Derek C. Bonham was end dated on 05/12/98 and not on 05/11/98 as was shown in our <br />submittal. Attachment 3-5 has been revised to include the correct end date. <br />Comment 7 - In tIx list of officers and drrmrns that had b,~t subnwal for tlx PfrL Carl Ho/dvtgs Corporation, <br />W. Houtml Carscut is lists[ as CCO, but as CFO vt A VS. 7be Dirnsicvt is not autne of arty such desigrmtian as <br />CC17 Phase provide a nsrisal suErrwlal page, o'xmging CCO to CFO, :f3uu agrre. <br />The official title for W. Howazd Cazson is Chief Commercial Officer and not CFO of P&L Coal <br />Holdings Corporation. It is my understanding from our corporate personnel that the CCO <br />designation is not accepted in the OSM-AVS database. <br />