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AGO NAT. RES. SECTION Fax:3038663558 Aug 26 '97 8:33 P.05 <br /> 7 <br /> paragraphs contain no factual averments and no admission or <br /> denial is required. <br /> 24 . The allegations in paragraph 24 contain legal argument <br /> which require no admission or denial . <br /> PERMIT RECLAMATION <br /> 25. The Division admits the allegations in the first <br /> sentence of paragraph 25. The Division admits the allegations of <br /> the second sentence except it denies that M&E\King performed <br /> reclamation work. In, regard to the third sentence, the Division <br /> denies that it refused to approve proposed work by MCR and, states <br /> that it advised MCR that funds received under the liquidation <br /> plan were public funds and that the Division was therefore <br /> required to satisfy Procurement Code requirements. Accordingly, <br /> only the Division could enter contracts and disburse the money <br /> from the liquidation plan for reclamation purposes. <br /> 26 . The Division admits that the liquidation plan refers to <br /> reclamation of the Coal Basin mine site and states that the plan <br /> speaks for itself. <br /> 27. The Division admits the allegations contained in the <br /> first sentence of paragraph 27. .As to the second sentence, the <br /> Division believes that it is unlikely the M&E work will be done <br /> by the and of the 1997 work season. <br /> 28 . The Division admits that it has performed reclamation <br /> work in 1995 and 1996, and that it has solicited bids for work in <br /> the 1997 reclamation season. The Division denies the allegations <br /> in the third sentence of paragraph 28. <br /> 29 . The Division admits that the liquidation plan refers to <br /> distributions to be made for reclamation purposes and states that <br /> the plan speaks for itself, The Division specifically denies <br /> that the effect of the plan to set a maximum amount owed by the <br /> Creditors' trust is "consistent with the MLRB permit bonding <br /> requirement . " <br /> 30. The Division admits the allegations contained in <br /> paragraph 30 . <br /> 31 . The Division denies the allegations contained in <br /> paragraph 31 , <br /> 32 . The Division is without information or belief as to the <br /> beliefs of MCR and Louis LaGiglia and accordingly, deny the <br /> allegations contained in paragraph 32. <br /> 33 . The Division admits that MCR and Louis LaGiglia by <br /> letter dated May 5, 1997, advised that they had been, sued by <br /> -4- <br />