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FROM :NRTURRL RESOURCES SEC. 303 866 36S8 1995,12-11 10:S7 #667 P.02/13 <br /> UNITED STATES BANKRUPTCY COURT DEC U <br /> 0m,cE Or r4-I r <br /> FOR THE DISTRICT OF COLORADO A r'ORN-11"r <br /> In lie: ) Bankrnptcy No. 92 11659 PAC <br /> (Chapter 11) <br /> MM3-CONTINENT RESOURCES, INC. ) Motion Control No. P 1 <br /> T.Y.N. 36-1475193 ) <br /> Debtor. ) <br /> PITKIN IRON CORPORATION'S RESPONSE TO <br /> THE COLORADO DIVISION OF MINE At S AND GEOLOGY'S <br /> SUPPLEMENT TO OBJECTION TO FMCIN IRON'S ADMENMTRATIVE CLAIM <br /> Pitkin Iron Corporation ("l'itkdn Iron") by its attorneys, Burns, Figa & Will, P.C., <br /> hereby responds to the SUPPLEMENT TO OBJECTION OF PrrICEN IRON'S <br /> ADMINISTRATIVE CLAIM filed by the Colorado Division of Minerals and Geology <br /> ("DMG"). <br /> 1. Background <br /> DMG's objection to Pitldn Iron's claim presents a truly unusual situation with regard to <br /> the relationship of the parties involved. Before the filing of its bankruptcy petition in February <br /> 1992, Mid-Continent Resources, Inc. ("MCR"), Debtor in this case, was involved in a coal <br /> mining operation in the mountains south of Carbondale, Colorado. Because of changing market <br /> conditions, the mine ceased production in 1991 and MCR "mothballed" the mine while it <br /> attempted to Iocate a buyer_ When a potential buyer was located, MCR sought protection tinder <br /> Chapter 11 to facilitate the sale. When the potential buyer of the mine assets pulled out in July <br /> 1992, the mine was taken out of "mothball" status and entered reclamation. The bankruptcy, <br />