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f <br /> L <br /> UNITED STATES BANKRUPTCY COURT <br /> 7 i <br /> FOR THE DISTRICT OF COLORADO <br /> In Re: Bankruptcy No. 92 11658 PAC <br /> (Chapter 11) <br /> MID-CONTINENT RESOURCES, INC. Motion Control No. P-1 <br /> T.I.N. 36-1475193 <br /> Debtor. <br /> DIRECT TESTIMONY OF ROBERT J. DELANEY <br /> 1. My name is Robert J. Delaney. I am vice president and comptroller of Pitkin <br /> Iron Corporation ("Pitkin"). <br /> 2. 1 prepared bills presented by Pitkin to Mid-Continent Resources ("Resources") for <br /> payroll services, purchases and equipment rental. A portion of these charges have not been paid <br /> and are the basis of the claim presented. <br /> 3. Pitkin is an independent corporate entity, and is not a subsidiary of Resources. <br /> Pitkin operates as a separate and distinct business entity, independent of Resources, and has done <br /> so historically. <br /> 4. Pitkin presently operates a steel fabrication and erection business, and holds <br /> various real estate properties. <br /> 5. In January, 1991, Resources was unable to continue worker's compensation <br /> coverage and discontinued coal production. The mine and other Resources' assets were offered <br /> for sale. <br /> 6. At the time Resources ceased coal production, Pitkin operated several other <br /> business enterprises. These included a limestone quarry and sizing/finishing plant, from which <br /> limestone products were produced and marketed, and also, a truck maintenance and repair <br /> service. <br />