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REQUESTS FOR ADMISSION <br /> Admission Request No.3. Admit that out;of the duties of Louis LaGiglia as the <br /> Creditors'Trustee is to timely file protests or requests for abatements as to taxes or interests <br /> assessed against property subject to the Creditors' Trust <br /> Response. Deny. Title to Mid-Continent Resources, Inc. ("MCR") real property <br /> was not transfered to the bankruptcy court liquidation PLA.\-'S Creditors' Trust. Such real <br /> property is encumbered by the PLAN's "irrevocable power of attorney' granted the <br /> Creditors' Trustee. Only sale proceeds of MCR real and personal property transfers to the <br /> Creditors' Trust. Therefore, the responsibility of protest or abatement relating to its ad <br /> valorem taxes remains the responsibility of MCR. <br /> Admission Request No.4. Admit that Louis LaGiglia as Creditors' Trustee is the <br /> only person who has authority under MCR! a liquidation plan to make decisions as to how <br /> to address past, present, or future tax assessments on real or personal property subject to <br /> the Creditors' Trust. <br /> Response. Deny. See response to Admission Request No. 3. <br /> Admission Request No,5. Admit that Louis LaGiglia as Creditors' Trustee is the <br /> only person who has authority under the liquidation plan to make decisions concerning <br /> disposition of real or personal property subject to the Creditors' Trust. <br /> Response. Deny.Both MCR and the PLAN's Creditors' Representatives have the <br /> authority and responsibility under the bankruptcy court liquidation PLAN to approve <br /> disposition of any asset,real or personal property,of a value in excess of$100,000.Further, <br /> all MCR personal property is enumerated on a bankruptcy court approved valuation <br /> schedule. Sales of such scheduled assets by the equipment liquidator must be for the <br /> scheduled price or with the approval of the Creditors' Trustee. <br /> Admission Request No. 6. Admit that Louis LaGiglia as Creditors' Trustee has <br /> not asked for all abatements allowed under law for interests accrued on taxes assessed by <br /> Pitkin County. <br /> Response. Deny. See response to Admission Request No. 3. <br /> MCR SUPPLEMENT TO <br /> CIVIL No.97 CV 131-1 -2- DMG INITIAL DISCOVERY <br />