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21. The Division admits that the liquidation plan refers to distributions to be made <br /> by the Creditors' Trustee for reclamation purposes and states that the plan speaks for itself. <br /> The Division states, however, that the liquidation plan sets forth more details and <br /> requirements regarding amounts to be taken against reclamation funds than those set forth in <br /> the allegations of paragraph 21. To the extent that the allegations contained in paragraph 21 <br /> incorporate legal argument, including but not limited to, use of the phrase "The effect of the <br /> Plan is to "cap" or set a maximum amount owed by the Creditors' Trust to DMG for Coal <br /> Basin mine property reclamation," no admission or denial is required. <br /> 22. The Division admits that the liquidation plan refers to "Reclamation Bond" and <br /> states that the plan speaks for itself. <br /> FIRST CLAIM FOR RELIEF <br /> (Injunction) <br /> 23. The Division incorporates all of its previous responses in this Answer as if set <br /> forth in full. <br /> 24. The Division has insufficient knowledge or information regarding the truth or <br /> veracity of the allegations in paragraph 24 and therefore denies the same. <br /> 25. The Division admits that at present time the reclamation plan requires demolition <br /> of the Lamp house, its power lines, a metal building near the former Preparation Plant, and a <br /> water tank. As to "access roadways," the Division is without sufficient knowledge or <br /> information regarding the meaning of the term"access roadways" so as to form a belief as to <br /> the truth or veracity of that part of the allegation and therefore denies the same. As to <br /> culverts for stream crossings, the Division will remove some of the culverts, but will leave <br /> others in place. The Division is without sufficient knowledge or information regarding the <br /> truth or veracity of the allegation that all of the "improvements" are located on property <br /> currently owned by MidCon Realty, LLC and-therefore denies the same. <br /> 26. The Division has insufficient information or knowledge to form a belief as to the <br /> truth or veracity of the allegations of paragraph 49 and therefore denies the same. <br /> 27. The Division admits that Robert Delaney sent a letter dated June 22, 199S, to <br /> Mike Long in which he mentions that it was expected that a number of post-mining land uses <br /> will be developed on the remaining private land in Coal Basin and that in this regard he states <br /> that "most of the remaining improvements and facilities will be needed and useful for these <br /> post-mining uses." Mr. Delaney specifically names the Lamphouse, power line leading to <br /> 4 <br />