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UNITED STATES BANKRUPTCY COURT Of <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 DIANE DELANEY <br /> 1. My name is Diane Delaney. I am Manager of Governmental Affairs for Mid- <br /> Continent Resources ("Resources"). <br /> 2. In 1993 and 1994 I supervised and directed reclamation, remediation and clean-up <br /> activities at various properties owned by Resources. <br /> 3. The reclamation crew I supervised consisted of employees who were carried on <br /> the Pitkin Iron Corporation ("Pitkin") payroll, in order to provide necessary worker's <br /> compensation coverage, and who had been retained from layoff by Resources and Pitkin because <br /> of specific background and skills which would be useful in performing liquidation and <br /> reclamation work. <br /> 4. I prepared time sheets which the reclamation crew were required to complete at <br /> the end of each day's work. These time sheets identified the work done, hours spent, and <br /> equipment used. <br /> 5. Specified items of equipment owned by Resources were held back from sale for <br /> use in the liquidation and reclamation activities. <br /> 6. In addition, Resources requested that Pitkin retain from sale various items of <br /> Pitkin's equipment and vehicles for use in reclamation and clean-up activities on Resources' <br /> properties. This equipment was retained for the use of Resources. <br />