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previous reclamation work conducted by entities other than the <br /> Division. Some of this work was performed poorly and required <br /> additional Division work. This is why the Division is adamant that <br /> the Trustee account for any further money he is paying or crediting <br /> for past reclamation work. Any credit taken by the Trustee affects <br /> the amount of distribution the Division will receive under the <br /> liquidation plan. <br /> In addition, it was clear last Spring that the Trustee did not <br /> understand that the credits could only be taken for work done <br /> pursuant to cash collateral orders prior to the effective date of <br /> the liquidation plan. However, that is the clear language of the <br /> liquidation plan. In order to resolve this claim, MCR and the <br /> Trustee must provide the Division with documentation that <br /> establishes that the $382, 000 is an allowable credit under the <br /> provisions of the liquidation plan. <br /> b. MidCon Realty, LLC' s Third-Party Complaint <br /> First Claim for Relief <br /> This claim is essentially the same as MCR and the Trustee' s <br /> fifth claim for relief . The claim requests the court to issue an <br /> injunction against demolition of certain improvements . The <br /> Division' s position is the same as that stated in response to MCR <br /> and the Trustee' s fifth claim. <br /> Second Claim for Relief <br /> The LLC' s second claim is based on its allegation that the <br /> liquidation plan is a contract, that the reclamation plan is <br /> incorporated into the liquidation plan, that the LLC is a third- <br /> 24 <br />