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REV99801
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REV99801
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Entry Properties
Last modified
8/25/2016 3:23:38 AM
Creation date
11/22/2007 12:30:55 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Revision
Doc Date
5/30/2007
Doc Name
Draft Order/Tatum Response
From
Ann Tatum
To
Davis Graham & Stubbs
Type & Sequence
SI1
Media Type
D
Archive
No
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Alvly TATUm <br />129 NORTH COMMERCIAL STREET <br />TRINIDAD, COLORADO 81082. <br />Phone: 719,846.0149 Fax.. 719 8460159 <br />May 30, 2007 <br />Scot Anderson <br />William Bianco <br />Attorney at Law ~ <br />Davis Cxraham & Stubbs LLP <br />1550 SCVCn1.CCIIlh SLTCgL, .Sillte J()t) <br />Denver, Colorado 8020,2 <br />RE: Tatum v Basin <br />Gentlemen: <br />Powell. <br />FACSIMILE: (303) 893-1379 <br />c~~`~~° <br />FEE otioo~ <br />Mpo o ~~a safey n, <br />D~~`M~~~n9 a <br />We are in receipt of the lvlay 30, 20071etter directed to Mr. Anderson from Tyson <br />Please correct me if I am in error, however it does appear that you are intending to <br />insert certain "key elements" into the Board's order that were not addressed by the Board. <br />There were twb separate issues addressed by the ]3oard on May 16'". Each is a <br />performance violatlon~and while they address the same issue to some degree they are not <br />the same. <br />The NOV that Basin received is cleaz on its face. Abatement is to conform to the <br />Judgment, $622,000.00 plus pre and post judgment interest. You are correct that the <br />Board did not include pre judgment interest with reference to the bond. At no tune did <br />the Board address any amount for abatement of the NOV. Mr. Anderson certainly had <br />the opportunity to request clarification of the Boazds order, he failed to do so. Mr. <br />Anderson did ask for the Board to abandon and rebuke the "law" with his request for an <br />extension of'the NOV, Whlch WiJS Cleazly a V1UlallVn Ur the JLkIIC a[ld fC[leml laW. <br />Jt is our position that for Basin to abate the NOV they must pay the judgment <br />amount, pre and post judgment interest. We do not intend to acknowledge that the N~V <br />has been abated for any less amount. <br />Z0 39Gd Wflltll WIP 65t09b86LL 6b :6L L00Z(0£(S0 <br />
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