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AGO NAT. RES. SECTION Fax:3038663558 Aug 26 '97 8:33 P.04 <br /> allegations contained in paragraph 13 and therefore denies the <br /> same. <br /> 14 . The Division admits that Answer Exhibit 1 attached to <br /> MCR and Louis Laoiglia' s Amended Answer is the M&E contract and <br /> that the liquidation plan refers to the contract and states that <br /> such documents speak for themselves. The Division admits that <br /> the Bankruptcy Court authorized, employment of the M&E. As to the <br /> other allegations in paragraph 14, the Division is without <br /> sufficient information and knowledge: regarding the truth or <br /> accuracy of the allegations and therefore denies the same. <br /> 15. The Division states that the provisions of the M&E <br /> contract cited in paragraph 15' speak for themselves. To the <br /> extent the allegations contained in this paragraph incorporate <br /> legal argument, the paragraph contains no factual averment and <br /> no admission or denial is required. <br /> 16. The provisions of the M&E contract cited in paragraph <br /> 16 speak for themselves. To the extent that the allegations <br /> contained in paragraph 16 incorporate legal argument, the <br /> paragraph contains no factual averment and no admission or denial <br /> is required. As to the second sentence, the Division states that <br /> it believes it is unlikely that the work required under the M&E <br /> contract will be completed by the end of the 1997 work season. <br /> BANKRUPTCY LIQUIDATION PLAN <br /> 17. The Division admits that a plan of liquidation was <br /> approved and confirmed by the Honorable Patricia A. Clark, that <br /> the amendments referenced in 17 a. , b. , c. , and d. are attached <br /> to MCR and Louis LaGiglia' s Amended Answer and Counterclaims, and <br /> that the Confirming order became final June 13, 1994, and that it <br /> became effective approximately 30 days later. Except as so <br /> admitted, the Division zs without sufficient information and <br /> knowledge regarding the truth or accuracy of the allegations in <br /> paragraph 17 and therefore denies the same. <br /> 18 . The Division, is without sufficient information and <br /> knowledge regarding whether the Confirming order and liquidation <br /> plan were recorded in the Clerk and Recorder' s Office in Pitkin <br /> County and therefore denies the same. The Division, admits the <br /> allegations in the second and third sentences of paragraph 1B. <br /> 19 - 23 . The Division admits that the liquidation plan <br /> includes the Coal Basin mine site; that it creates a creditors' <br /> Trust and establishes a Creditors' Trustee; that two Creditor <br /> Representatives are to supervise the Creditors' Trustee; and that <br /> the plan provides for disposition of the debtor' s property and <br /> that such liquidation plan speaks for itself. To the extent the <br /> allegations in these paragraphs incorporate legal argument, the <br /> -3- <br />