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f�f UNITED STATES BANKRUPTCY COURT FOR TH `'=' <br /> DISTRICT OF COLORADO <br /> In re. <br /> MID-CONTINENT RESOURCES, INC. ) Case No. 92 11658. .PAC i <br /> T.I.N. 36-1475193 ) Chapter 11, M.C. No. H&J-8 <br /> Debtor. ) <br /> RESPONSE TO COLORADO DIVISION OF MINERALS AND GEOLOGY'S <br /> OBJECTION CONCERNING DEBTOR'S APPLICATION TO EMPLOY SPECIAL <br /> COUNSEL (PARCEL, MAURO, HULTIN & SPAANSTRA, P.C. ) <br /> Mid-Continent Resources, Inc. , debtor in possession, <br /> through its attorneys, Holden & Jessop, P.C. , responds as follows <br /> to the Objection (the "Objection" ) of the Colorado Division of <br /> Minerals and Geology (the "DMG" ) to the Debtor's Application to <br /> Employ Special Counsel (Parcel, Mauro, Hultin & Spaanstra, P.C. ) <br /> (the "Application" ) : <br /> 1. The Application seeks to employ special counsel <br /> familiar with mine reclamation to represent the Debtor with respect <br /> to the following matters: <br /> a. Representation of the Debtor's interest in <br /> litigation brought by the DMG against the Debtor's <br /> corporate parent and certain officers, directors, and <br /> employees (the "DMG Litigation" ) , including but not <br /> limited to possible intervention in that action; <br /> b. Representation of -he Debtor with respect to the <br /> reclamation schedule applicable to the Debtor; <br /> C. Representation of the Debtor with respect to the <br /> extent of the Debtor's reclamation oblication under the <br /> Debtor's reclamation plan or applicable federal or state <br /> law; and <br /> d. Representation of the Debtor with regard to any <br /> citations or notices of violation issued by a <br /> governmental unit, federal or state, with regard to mine <br /> reclamation, mine maintenance or the like. <br /> 2 . The Objection appears to be limited to item (a) <br /> above. The Debtor thus limits this response to matters pertaining <br /> to the DMG Litigation. This first requires an understanding of the <br /> Debtor's reclamation obligation, as it arises under statute, as it <br /> has been interpreted in the bankruptcy context, and as it has been <br /> enforced by the DMG and other state agencies. <br />