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1997 prepared by Gregory C. Lewicki, P.E., Denver, Colorado, in six unnumbered letter-
<br /> sized pages and eight unnumbered legal-sized pages, and provided to Third-Party
<br /> Defendant December 9, 1997 pursuant to the Court's Case Management Order.
<br /> Letter to Mid-Continent Resources,Inc.from Colorado Department of Labor and
<br /> Employment, Oil Inspection Section, dated August 26, 1997.
<br /> Interrogatory No.8. Identify the person(s)on whose advice or consultation you
<br /> relied for your answers to Interrogatories 4 and 6.
<br /> Response to Interrogatory No. 8. Robert Delaney, Esq., Louis M. LaGiglia,
<br /> Gregory C. Lewicki, P.E., and Leonard Wardlaw.
<br /> InterrogatorNo. 9. State the factual or legal basis for defendants' allegation,
<br /> pleading, statement, belief, or contention in the Defendants' Amended Answer and
<br /> Counterclaims (no. 81) and in the Third-Party Complaint (no. 31) that the Creditors'
<br /> Trustee, Louis LaGiglia, has in cash or credits paid or accrued an aggregate bonding
<br /> equivalent in the sum of $2,384,112.81, for the use and benefit of DMG and\or its
<br /> reclamation fund. Include in your answer a breakdown of the$2,384,112.81,into separate
<br /> categories for cash paid towards the reclamation fund and credit accrued taken against the
<br /> fund,and identify the specific work done for which credit is taken against the reclamation
<br /> fund.
<br /> Response to Interrogatory No.9. The total cash paid by the Creditors'Trustee
<br /> in connection with mine reclamation is $1,884,112.81. Of this amount, $1,501,607.72 was
<br /> paid to DMG, and $382,504.99 was paid for mine reclamation work prior to the DMG
<br /> reclamation take-over; $101,500.00 was spent for portal sealing, and the balance for actual
<br /> reclamation work principally at the Coal Basin No. 5 mine site. A credit of $500,000.00 is
<br /> taken or added to the sum of$1,884,112.81 for the reclamation/remediation work performed
<br /> by the liquidation contractor,M&E/King,under the M&E/KI:\G CONTRACT as approved by
<br /> the bankruptcy court.
<br /> Interrogatory No. 10. Identify any and all documents which were referred to or
<br /> relied upon to support the allegation, pleading, statement, belief, or contention that the
<br /> Creditors' Trustee, Louis LaGiglia, has in cash or credits paid or accrued an aggregate
<br /> bonding equivalent in the sum of$2,384,112.81 for the use and benefit of DMG and\or its
<br /> reclamation fund.
<br /> Response to Interrogatory No. 10. The Creditors' Trustee provided an
<br /> accounting to DMG relating to reclamation matters September 18, 1996. Included in that
<br /> MCR RESPONSES TO
<br /> CIvIL No.97 Cv 131-3 -10- DMG INITIAL DISCOVERY
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