1993-08-10_GENERAL DOCUMENTS - C1981017

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 8/10/1993
• Doc Name: DMGs Concerns about the proposed plan
• From: Attorney Generals Office
• To: James Holden
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

Gale A. Norton
Attorney General
Raymond T. Slaughter
Chief Deputy Attorney General
Timothy M. Tymkovich
Solicitor General
James B. Holden
303 East 17th Ave., #930
Denver, Colorado 80203
Dear Jim:
011p tat of Cnulurabu
DEPARTMENT OF LAW
OFFICE OF THE ATTORNEY GENERAL
August 6, 1993
AU G1 0 1 9 93
STATE SERVICES BUILDING
1525 Sherman Street - 5th Floor
Denver, Colorado 80203
Phone [phone] & 866 -3611
FAX [phone]
RE: Mid - Continent Resources, DMG's concerns about the proposed
plan
Over the past several months we have discussed several issues
that need to be resolved in this case before confirmation of the
plan. This is to provide you with a written list of DMG's con-
cerns for your convenience, and to confirm several items that
were discussed or agreed to by MCR and DMG.
1. DMG asked MCR to retain an individual with engineering quali-
fications to provide DMG with designs and a stability analysis as
necessary for MCR's reclamation plan. This matter is under con-
sideration by MCR and we anticipate a response shortly.
2. MCR agreed to provide DMG with copies of all schedules of
monthly expenses since the filing of the petition, copies of the
invoices submitted by Pitkin Iron, and copies of the hourly
statements prepared by the Pitkin employees describing their
labors at the site. I would also like an estimation of the total
post - petition claim that is likely to be filed by Pitkin Iron,
and a description of all other post - petition claims that MCR
knows about that are not described in the disclosure statement
filed on July 20, 1993.
3. You have also agreed to provide me with a copy of the sales
price list covering the equipment subject to the M &E contract,
subject to a confidentiality agreement.
4. MCR has agreed to amend the proposed plan to increase the
amount deposited in the reclamation account by $7,000 in exchange
for the transfer of the Colorado Meadows Industrial Park property
to the Creditors' trust free and clear of DMG's encumbrance