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l <br /> BURNS, FIGA & WILL, P.C. <br /> Cheryl Linden <br /> June 9, 1995 <br /> Page 8 <br /> Vacation is part of the employment compensation package of all Pitkin Iron employees. <br /> Vacation pay was charged to MCR according to the time accrued when the employee was <br /> working for MCR. This is consistent with apportioning gross pay between MRC and Pitkin <br /> according to the percentage of time worked, and was applied to all the employees, not just two <br /> individuals. <br /> 4. Pitkin Iron requests to be paid for water samplings done by Lew Thompson. However, <br /> under MCR's liquidation plan, there is an environmental account which is to be used for <br /> monitoring and treatment of water discharging from the mine site. Indeed, an accounting <br /> from the Creditor's Trustee, Louis LaGiglia, shows that funds have been paid for <br /> compliance with water quality requirements, including water monitoring. Please explain <br /> whether Mr. Thompson was paid from the environmental account, and how much. The <br /> cost of water quality compliance should be paid from this account and not sought as an <br /> administrative expense. <br /> Response: Pitkin Iron's claim and the payment of Mr. Thompson's salary within this claim <br /> arise from a period of time prior to the effective date of the liquidation plan (July 1994) under <br /> which the environmental fund was established. This fund is administered by Mr. LaGiglia, the <br /> Trustee. Pitkin Iron did not pay Mr. Thompson from the environmental account, nor has Pitkin <br /> Iron been reimbursed from the environmental account. Whether the account should be credited <br /> for Mr. Thompson's salary is an internal accounting matter for MCR. <br /> I assume that the accounting from Mr. LaGiglia to which you refer would be for the <br /> period after July 1994, which is beyond the time covered in Pitkin Iron's claim (September 1993 <br /> to July 1994). <br /> 5. The reasoning in Paragraph four applies to the costs sought to be paid for removal of oil. <br /> The accounting statement for the environmental account shows that money was paid for <br /> oil removal. Is there any overlap between this payment and the costs for which Pitkin <br /> Iron now seeks to be paid? <br /> Response: The bill was paid by Pitkin Iron, is part of this claim, was not paid from the <br /> environmental account, nor has Pitkin Iron been reimbursed. <br /> 6. Are there costs being sought by Pitkin for any remediation of the rockdust plant? <br /> Response: No. Clean-up at the rockdust plant has not been billed to MCR. <br />