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GENERAL43778
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Last modified
8/24/2016 8:12:35 PM
Creation date
11/23/2007 12:38:14 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977376
IBM Index Class Name
General Documents
Doc Date
5/3/1993
Doc Name
REPLY TO DEBTORS OBJECTION TO MLRB MOTION DATED 4/2/93 FOR PAYMENT OF ADMINISTRATIVE EXPENSE
Media Type
D
Archive
No
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& 1992 Supp.) Accordingly, the $490 annual fee should be afford- <br />ed a priority as an administrative expense even if the motion to <br />abandon the quarries is granted. <br />The Debtors have not objected to the allowance of the an- <br />nual fee as an administrative expense if the motion to abandon <br />the quarries is denied. Accordingly, the Hoard's motion for pay- <br />ment of the fee as an administrative expense should be granted <br />upon denial of Debtors' motion to abandon the Monarch Quarries. <br />COST OF RECLAMATION <br />The Hoard has also asserted that the cost of reclaiming the <br />quarries is entitled to a priority as an administrative expense. <br />This issue has already been discussed, in part, in the briefs on <br />motions currently pending before the Court. See, e.g., Colorado <br />Mined Land Reclamation Board's Written Closing Arguments Dated <br />December 18, 1993 Concerning Hearing Held on December 9, 1993 <br />(hereinafter referred to as "Board's Closing Brief"). Much of <br />the testimony at the December 9, 1992 hearing was devoted to the <br />estimation of the cost of reclamation, and to the extent to which <br />an unreclaimed site will pose a threat to public health and <br />safety. The pending motion filed by the Debtors to abandon the <br />quarries, and the evidence introduced at the December 9, 1992 <br />hearing, are relevant to this motion to grant an administrative <br />priority to the cost of reclamation. <br />-3- <br />
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