Laserfiche WebLink
2 . The Plaintiffs' claims are barred by waiver and <br /> estoppel and by the specific fact that Plaintiffs consented to <br /> the transactions alleged herein. <br /> 3 . Plaintiffs' claims are barred by applicable <br /> statutes of limitation. <br /> 4 . Plaintiffs have released any claim that they may <br /> have, <br /> 5. Plaintiffs have received substantial payments on <br /> said promissory notes. <br /> WHEREFORE, having fully answered Plaintiffs' Complaint <br /> these Defendants and specifically Resources request that said <br /> claims on the promissory notes be dismissed and Plaintiff take <br /> nothing by way of them and Defendants Mid-Continent Resources, <br /> Inc. , a Delaware corporation, Mid-Continent Coal and Coke <br /> Company, a Delaware corporation, and Mid-Continent Minerals, <br /> Inc. , a Delaware corporation, request that Plaintiffs claims on <br /> fraudulent conveyance be dismissed and that Plaintiff take <br /> nothing by way of its Complaint and that these Defendants have <br /> its costs, attorneys fees, and such other and further relief as <br /> the Court may deem appropriate. <br /> SH�1 & HOWARD <br /> By: <br /> Craig A. Chris e-:isen <br /> 2900 First Interstate Tower North <br /> 633 Seventeenth Street <br /> Denver, Colorado 80202 <br /> Telephone: (303) 297-2900 <br /> Attorneys for Defendants <br /> Address of Defendants: <br /> Mid-Continent Minerals Corporation <br /> P.O. Drawer 790 <br /> 818 Colorado Avenue <br /> Glenwood Springs, Colorado 81601 <br /> Mid-Continent Resources, Inc. <br /> c/o Robert Delaney as <br /> Registered Agent for Service of Process <br /> Drawer 790 <br /> Glenwood Springs, Colorado 81601 <br /> -4- <br />