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1998-12-21_GENERAL DOCUMENTS - C1981017
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1998-12-21_GENERAL DOCUMENTS - C1981017
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Last modified
3/13/2021 4:39:45 PM
Creation date
5/2/2012 2:23:19 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
12/21/1998
Doc Name
Objection to motion to intervene and in the alternative motion to strike
From
US District Court
To
Mid-Continent Resources, Inc. & DMG
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
Tags
DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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In the meantime, although the Division believed the discussions with MCR and the <br /> Trustee were productive, MCR and the Creditors' Trustee chose to terminate talks and in <br /> August 1998 moved to file an amended third-party complaint. Over the Division's objection, <br /> this Court allowed the amendment on September 14, 1998. <br /> The September 1998 amended third-party complaint alleges six claims for relief; one <br /> of which requests injunctive relief against demolition of certain structures called for by the <br /> reclamation plan. The complaint asserts that Midcon Realty, LLC "has expressed a desire to <br /> use the improvements for post-mining uses and does not want [the structures] destroyed." <br /> Complaint at paragraph 49. The complaint further alleges that the Trustee sold the land to <br /> the LLC on the condition that he would "protect property values by preventing destruction of <br /> improvements required for post mining uses." Complaint at paragraph 49. <br /> Based on this allegation, in order to avoid a substantial risk of the Division <br /> potentially incurring multiple, inconsistent reclamation obligations by reason of any claimed <br /> property interest by the LLC, the Division believes that the LLC should be made a party in <br /> this matter pursuant to C.R.C.P. 19. Pitkin County agrees that the LLC should be joined as a <br /> party and has so stated in its Motion For Leave to File and Serve a Supplemental Pleading <br /> and to Join Additional Parties. <br /> However, rather than have this Court join the LLC as a party under C.R.C.P. 19, the <br /> LLC, through the same attorney who represents MCR and the Trustee, requests that this wort <br /> allow it to intervene as a third-party plaintiff under C.R.C.P. 24. It appears the only purpose <br /> in proceeding by intervention rather than by joinder is to allow the LLC to interject <br /> 3 <br />
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