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r <br /> negotiated and agreed upon between MCR and DMG subsequent to the initial approval of the <br /> permit. In response to interrogatories submitted by MCR to DMG in this matter, DMG has stated <br /> that the Reclamation Plan for Coal Basin includes the entire eleven volume set as well as additional <br /> subsequent amendments. See DMG responses to Interrogatories 2 and 3, attached as Exhibit A. To <br /> suggest that this massive amount of material should have been submitted to the bankruptcy court, <br /> much less requesting that the bankruptcy judge review the information and make a determination as <br /> to the adequacy of the Reclamation Plan, is Unrealistic. Obviously, the bankruptcy court has no <br /> time, interest or expertise to make such a review and evaluation. What is significant about the <br /> Liquidation Plan, and its reference to the Reclamation Plan, is the fact that the Liquidation Plan was <br /> the subject to extensive negotiations between DMG and MCR. In fact, after submitting its Second <br /> Amended Plan of Reorganization, MCR agreed to three additional amendments to that Liquidation <br /> Plan at the insistence of DMG. See, for example, March 24, 1994 letter from Assistant Attorney <br /> General Cheryl Linden to MCR's bankruptcy counsel, James Holden (copy attached as Exhibit B) <br /> requesting changes to MCR's Liquidation Plan. The Second Amended Liquidation Plan, which <br /> was finally confirmed by the bankruptcy court, is attached as Exhibit C, and the three amendments <br /> requested by DMG are attached as Exhibits D, E and F, respectively. The bankruptcy court's orde <br /> confirming the Second Amended Plan of Liquidation as amended is attached as Exhibit G. <br /> An additional irony of DMG's position is that the Reclamation Plan itself was neg <br /> long before the bankruptcy was ever filed and in fact, the office of Mined Land Reclama' <br /> statutory duty to ensure that reclamation plans in all mining permits are adequate <br /> statutory requirements. C.R.S. § 34-33-111 & 114(2)(b). Further, DNIG' <br /> Interrogatory 2 (Exhibit A) sho%,N•s quite clearly that DMG knows and Lind <br /> Reclamation Plan is. Further, the applicable statutes and regulations requ, <br />