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UNITED STATES BANKRUPTCY COURT <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 /> SUPPLEMENTAL DIRECT TESTIMONY OF LOUIS M. LAGIGLIA <br /> 1. My name is Louis M. LaGiglia. I reside at Glenwood Springs, Colorado. <br /> 2. I have been a Certified Public Accountant since 1971. For twenty (20) years, I <br /> have affiliated with public accounting firms, devoting much of my time to audit work for <br /> corporations, individuals and municipalities. Since 1987, I have been Vice President, Treasurer <br /> and Chief Financial Officer for Mid-Continent Minerals Corporation and subsidiaries including <br /> Mid-Continent Resources, Inc. ("Resources"). In that capacity, it was my duty and <br /> responsibility to manage the finances of Resources, Inc., including arranging cash flow to meet <br /> debts and obligations, securing credit where cash flow was inadequate, auditing and payment of <br /> bills and participating in decisions concerning the bankruptcy and liquidation of assets for <br /> Resources. <br /> 3. In that capacity, I participated in arrangements for extension of Credit by Pitkin <br /> Iron Corporation ("Pitkin") to perform environmental work required by law; to maintain the <br /> mine site; to abate violations cited by the Colorado Division of Minerals and Geology <br /> ("CDMG"); to provide clean up services and environmental remediation services on tracts of <br /> land to be liquidated to pay bankrupt debts. <br /> 4. Pitkin was used in this capacity because Resources did not have funds to perform <br /> these functions; did not have credit, workmen's compensation was cut off and it would have <br /> been impossible to perform Chapter 11 debtor-in-possession responsibilities without the aid and <br /> assistance of Pitkin. <br />