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13. The Division admits that Answer Exhibit 1 attached to MCR's and Louis <br /> LaGiglia's Amended Answer is the M&E contract and that the liquidation plan refers to the <br /> contract and that such documents speak for themselves. The Division admits that the <br /> Bankruptcy Court authorized employment of M&E. As to the other allegations contained in <br /> paragraph 13, the Division is without sufficient information and knowledge regarding the <br /> truth or accuracy of the allegations and therefore denies the same. <br /> BANKRUPTCY LIQUIDATION PLAN <br /> 14. The Division admits that the Honorable Patricia A. Clark approved and <br /> confirmed a plan of liquidation; that the amendments referenced in 14 a., b., c., and d. are <br /> attached to MCR's and Louis LaGiglia's Amended Answer and Counterclaims; that the <br /> Confirming Order became final June 13, 1994 and became effective approximately 30 days <br /> later; and that such documents speak for themselves. Except as so admitted, the Division is <br /> without sufficient information and knowledge regarding the truth or accuracy of the <br /> allegations contained in paragraph 14 and therefore denies the same. <br /> 15. The Division is without sufficient information and knowledge regarding whether <br /> the Confirming Order and liquidation plan were recorded in the Clerk and Recorder's Office <br /> in Pitkin County and therefore denies the same. The Division admits the allegations in the <br /> second and third sentences of paragraph 15. <br /> 16 and 17. The Division admits that the liquidation plan refers to the Coal Basin mine <br /> site; that it creates a Creditors' Trust and establishes a Creditors' Trustee; that two Creditor <br /> Representatives are to supervise the Creditors' Trustee; and that the plan provides for <br /> disposition of MCR's property; and states that such liquidation plan speaks for itself. To the <br /> extent the allegations in these paragraphs incorporate legal argument, no admission or denial <br /> is required. <br /> PERMIT RECLAMATION <br /> 18. The Division admits the allegations in the first sentence of paragraph 18. The <br /> Division admits the allegations of the second sentence except it denies that M&E\King <br /> performed reclamation work. In regard to the third sentence, the Division denies that it <br /> refused to approve proposed work by MCR and states that it advised MCR that funds <br /> received under the liquidation plan were public funds and that the Division was therefore <br /> required to satisfy state Procurement Code requirements. Accordingly, only the Division <br /> could enter contracts and disburse money from the liquidation plan for reclamation purposes. <br />