1996-12-02_GENERAL DOCUMENTS - C1981017

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DEC 02 '96 10:53AM DIV/MINERALS&GEOLOGY P.2f4 Y � OFFICE OF GENERAL COUNSEL MID,CONTINENT RESOURCES, INC, F.o.DRAWOL 790 n E C E I V E D SIS COLD ADO AVENUE TELEPHONE GLENWOOD SPRINGS.COLORAW 81602 FAX A"A CODE 303 NOV 2 9 1996 AREA �3 915.2303 H5.6w �lLl lG^cc Ct'gioi21sL&Gaolosgy November 26, 1996 Ms. Deborah Quinn Assistant County Attorney 530 East Main Street, Suite 302 Aspen, CO $1911 Dear Ms . Quinn: Reference is made to your letter of November 20, 1996 stating in substance that unless the Banks uptcy' Trustee applies escrowed funds and future sales proceeds on Schedules 7863 and 4062, that you will file a Motion to re-open the bankruptcy case . For reasons covered in previous correspondence, we believe the ,Trustee is following precisely the provisions of the Bankruptcy Liquidation Plan, which contemplated application of liquidation proceeds to reclamation, environmental remediation, and other work needed to make the property saleable with payment of property taxes to come out of the residue except where the tax was a lien on a specific piece of property or where the loss of property was threatened by tax. deed. If the Bankruptcy Court orders otherwise, the Trustee will., of course, comply. We repeat, that we believe your proceeding is unnecessary; that orderly liquidation of the property in accordance with the Plan as written will result in payment of all taxes; that your proposed procedure is counter productive in terms of facilitating liquidation of the property or completion of reclamation and is inappropriate. We appreciate the Treasurer sending a re-capitulation of their calculation of taxes. We do not agree with it, possibly because we do not fully understand it . We will communicate with the Treasurer in the hope of reconciling these computations .