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1997-07-31_GENERAL DOCUMENTS - C1981017 (2)
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1997-07-31_GENERAL DOCUMENTS - C1981017 (2)
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2/28/2021 9:49:01 AM
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DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
7/31/1997
Doc Name
Civil Action No. 97-CV-131 Plaintiff Reply to Defendants Amended Answer and Counterclaim
From
District Court County of Pitkin
To
Mid-Continent Resources Inc
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
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16. Plaintiffs admit ,::at .-answer Exhibit 1 is a copy of the M & E/King <br /> Contract, that the Contract is :cciuded in the Plan. that the Contract and the Plan speak <br /> for themselves. that the Contrac: makes no provision for the payment of any ad valorem <br /> property taxes, and except Ls so admitted. are without knowledge or information <br /> sufficient to form a belief as to tn:- math of the averments of paragraph 66. <br /> 17. Plaintiffs admit :::at the provision of M & E/King Contract set out in <br /> paragraph 67 of the Answer s :: :art of M & E/King Contract. that the Load-Out Site, the <br /> Carbondale Industrial Park Carbondale Fabrication Shop are located in Garfield <br /> County, Colorado. and excec: Ls so admitted. are without knowledge or information <br /> sufficient to form a belief as tot e ,ruth of the averments of paragraph 67. <br /> 17. Plaintiffs admit :::at the M & E/King Contract provisions are as set forth in <br /> paragraph 68. that such provisions speak for themselves. and except as so admitted. are <br /> without knowledge or information sufficient to form a belief as to the truth of the <br /> averments of paragraph 68. <br /> 18. Plaintiffs are v.urout knowledge or information sufficient to form a belief <br /> as to the truth of the averments o raragraph 69. <br /> 19. Plaintiffs admit t^at M & E/King sold some of MCR's mining equipment <br /> and personal property, and except as so admitted, are without knowledge or information <br /> sufficient to form a belief as to the truth of the averments of paragraph 70. <br /> 20. Plaintiffs admit ::a: a plan of liquidation entitled "Second Amended Plan <br /> of Liquidation" was appro%ed and confirmed by Honorable Patricia A. Clark, that the <br /> amendments referenced in raracraph 71. a.. b.. c., and d. were attached. that the <br /> Confirming Order became fmai June 13. 1994 and effective thirty (30) days thereafter. <br /> and except as so admitted. a:e v.uhout knowledge or information sufficient to form a <br /> belief as to the truth of the a%e:-::en s of paragraph 71. <br /> 21. Plaintiffs admit averments of paragraph 72. <br /> 22. Plaintiffs admit ,-at the Plan refers to the M & E/King Contract in <br /> Sections 1.19 and 1.20. as Weil as in Section 6.25. state that the Plan speaks for itself, and <br /> except as so admitted. deny the averments of paragraph 73. <br /> 23. Plaintiffs admit i` at the sections of the Plan set out in paragraph 74 make <br /> provision for a creditors' trustee. creditor representatives, administration of a creditors' <br /> trust, supervision by creditors' -epresentatives. and provisions for removal, that such <br /> provisions of the Plan speak for themselves, and except as so admitted. are without <br /> knowledge or information ,utticient to form a belief as to the truth of the averments of <br /> paragraph 74. <br /> 3 <br />
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