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DISTRICT COURT, COUNTY OF PITKIN, STATE OF COLORADO RECEVED <br /> Case No. 97-CV-131-3 <br /> i <br /> -- 0FFI -E OF 7 7 <br /> ATTORNEY GEAl '-AL <br /> REPLY IN SUPPORT OF MOTION TO INTERVENE NAnq?.ALRESOURE b:BAN <br /> BOARD OF COUNTY COMMISSIONERS OF PITKIN COUNTY, COLORADO, AND <br /> THOMAS CARL OKEN, PITKIN COUNTY TREASURER, <br /> Plaintiffs, <br /> V. <br /> MID-CONTINENT RESOURCES, INC., and LOUIS M. LAGIGLIA, <br /> CREDITORS' TRUSTEE UNDER BANKRUPTCY PLAN OF LIQUIDATION, <br /> Defendants and Third-Party Plaintiffs, <br /> V. <br /> STATE OF COLORADO, DEPARTMENT OF NATURAL RESOURCES, DIVISION <br /> OF MINERALS AND GEOLOGY, <br /> Third-Party Defendant. <br /> MidCon Realty, LLC ("MidCon"), by its attorneys Burns, Figa& Will, P.C., hereby files this <br /> Reply in Support of its Motion to Intervene. <br /> I. INTRODUCTION <br /> 1. Third-Party Defendant, State of Colorado, Department of Natural Resources, Division <br /> of Minerals and Geology ("DMG") has apparently failed to heed the old adage "be careful what you <br /> wish for, you just might get it." After agreeing with Plaintiff, Pitkin County's Motion for Leave to <br /> File and Serve a Supplemental Pleading and to Join Additional Parties that MidCon should be a <br /> third-party plaintiff(See DMG's response to 1\4otion for Leave to File and Serve a Supplemental <br /> Pleading and to Join Additional Parties), DMG now seeks to ensure MidCon's attendance in this <br />