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AGO NAT. RES. SECTION Fax:3038663555 Aug 26 '97 8:32 P.03 <br /> ORIGINAL ACTION <br /> 4. The Division admits that the Plaintiffs commenced this <br /> action and state that the Plaintiffs' complaint speaks for <br /> itself. <br /> 5. The Division admits that the MCR and Louis LaGiglia have <br /> responded to the Plaintiffs' Complaint and states that their <br /> Amended Answer and Counterclaims speaks for itself. <br /> INITIATORY PLEADINGS (SEPARATE COPIES) <br /> 5 . The Division admits that it has received a copy of the <br /> Plaintiffs' Complaint, MCR and Louis LaGiglia' s Amended Answer <br /> and Counterclaims, and Third-Party Complaint. The second <br /> sentence of this paragraph does not contain factual averments to <br /> which admission or denial is required. <br /> BACKGROUND <br /> 7. The Division is without sufficient information and <br /> knowledge regarding the truth or accuracy of the allegations <br /> contained in paragraph 7 and therefore denies the same, except <br /> the Division admits that MCR operated an underground coal mine in <br /> Coal Basin. <br /> 8 . The Division is without sufficient information and <br /> knowledge regarding the truth or accuracy of the allegations <br /> contained in paragraph 8 and therefore denies the same, except <br /> the Division admits that a fire occurred at the Coal Basin mine, <br /> 9 . The Division admits the allegations in paragraph 9. <br /> MCR BANKRUPTCY FILING <br /> 10 and 11 . The Division admits that MCR filed a petition in <br /> bankruptcy on February 12, 1992, and that the Division was a <br /> creditor and party in interest in the bankruptcy proceeding, and <br /> states that the filing speaks for itself. <br /> 1M&E/KING CONTRACT <br /> 12 . The Division admits that MCR petitioned the bankruptcy <br /> court for authority to employ Machinery and Equipment Co. , Inc. , <br /> and states that the petition speaks for itself. <br /> 13. The Division admits that the motion to employ M&E was <br /> supplemented by a subsequent motion, and as to the rest of the <br /> allegations in paragraph 13 states that it is without sufficient <br /> information and knowledge regarding the truth or accuracy of the <br /> -2- <br />