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Dudash, Joe <br />From: Cramer, Johanna <br />Sent: Monday, July 18, 2011 3:29 PM <br />To: Dudash, Joe <br />Subject: RE: TerrorCreek MR26ResponseMemo.docx <br />Joe, <br />It's too late to call AVS, but I would like to do that and discuss this with them and give you my answer. Will that work? <br />Thanks <br />Johanna Cramer <br />Corporate Compliance /Bonding Specialist <br />Division of Reclamation, Mining and Safety <br />303 - 866 -3567, extension 8114 <br />From: Dudash, Joe <br />Sent: Monday, July 18, 2011 2:57 PM <br />To: Cramer, Johanna <br />Subject: RE: TerrorCreek MR26ResponseMemo.docx <br />When you and 1 had discussed this, we concluded that there was an exemption under Rule (83a)(b) when it could be <br />demonstrated that the person has no direct or indirect control of the loadout's operations. Why would they have to <br />show no control if they submit a list of officers and directors? The idea of showing no control is so that they wouldn't <br />have to provide the list of officers and directors. Please explain. <br />From: Cramer, Johanna <br />Sent: Monday, July 18, 2011 2:39 PM <br />To: Dudash, Joe <br />Subject: RE: TerrorCreek MR26ResponseMemo.docx <br />They still have to submit officers and directors because they own 22 % of Oxbow, then they still need to show they have <br />no control. Under new rules they wouldn't but we aren't under the new rules and that's what I discussed with Susan <br />who discussed with Sandy. <br />Johanna Cramer <br />Corporate Compliance /Bonding Specialist <br />Division of Reclamation, Mining and Safety <br />303 - 866 -3567, extension 8114 <br />From: Dudash, Joe <br />Sent: Monday, July 18, 2011 1:50 PM <br />To: Cramer, Johanna <br />Subject: RE: TerrorCreek MR26ResponseMemo.docx <br />I have one question concerning your memo. Your first request is that Oxbow supply the names etc of the officers and <br />directors of Oxbow- Crestview so that they can be put into AVS. However, the reason why Oxbow is attempting to show <br />that Crestview does not control the operations of the Terror Creek Loadout is so that Oxbow does not have to supply all <br />of the names for Crestview, per Rule 83a)(b). Apparently, there are a lot of names. So can I just forward your second <br />request for more information? <br />