1993-09-20_GENERAL DOCUMENTS - C1981017

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FROM :AGO NAT. RES. SECTION TO 303 860 7233 1993.05-20 10.37 #SS3 P.02/10 40 Y• 'S •-�'.4•s^ •i• j'e;r;t '• - tea'=:'mil �:��. •1....; �i DISTRICT COURT, PITRIN COUNTY, COLORADO Case No. 93 CV COMPLAINT ------------------- ------ ---- ----- DIVISION OF MINERALS AND GEOLOGY, DEPARTMENT OF NATURAL RESOURCES, STATE OF COLORADO, Plaintiff, V. JOBN A. REEVES; ROBERT DELANEY; DIANE D MANEY; AND KID-CONTINENT MINERLLS CORPORATION Defendants. ------ ---------—---------------------The Division Division of Minerals and Geology of the Department of Natural Resources of the State of Colorado ("the Division") , by and through the Attorney General for the State of Colorado, hereby complains against the defendants as follows: I. Mid-Continent Resources, Inc. ("Resources") , a Delaware corporation, operated a coal mine known as the Coal Basin Mine in Pitkin and Gunnison Counties. Resources is a wholly awned sub- sidiary of Mid-Continent Minerals Corporation ( "Minerals") . 2. Coal mining operations at the Coal Basin Mine were cov- ered by a mining and reclamation permit, permit number C-81-017, issued to Resources by the Division in 1983. The operation was subject to the provisions of the Colorado Surface Coal Mining Reclamation Act ( "CSCNMA") , SS32-33-101 through 137 (1984 & 1992 Supp. ) , and regulations promulgated thereunder. 3. Pursuant to S 34-33-113, C.R.S. (1984) , an operator must provide the Division with a performance bond to ensure reclamation. In 1984, Resources provided the Division with such a bond in the form of a deed of trust encumbering certain prop- erty in Garfield County. The performance bond was personally obtained by John A. Reeves who signed the deed of trust as presi- dent of Resources. The deed of trust was subsequently released by the Division in May 1989 after the deed of trust was replaced EXHIBIT B