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04/01/99 18:28 FAX 3037962777 BURNS FIGA & WILL Z 002 <br /> BURNS, FIGA & WILL, P.C. <br /> ATTORNEYS AT LAW <br /> PLAZA TOWER, SURE 1 030 <br /> 0400 SOUTH FIDDLER5 GREEN CIRCLE <br /> ENGLEWOOD. COLORADO 801 1 1 <br /> GEOFFREY P_ ANDERSON April I 1999 TELEPHONE (303) 796-2625 <br /> FACSIMILE l303) 79e-2777 <br /> DIRECT (30. 414-8999 <br /> VIA FACSIMILE & FIRST CLASS Ni TAIL: <br /> (303) 866-3558 <br /> Cheryl A.Linden, Esq. <br /> Office of the Attorney General <br /> Natural Resources Section <br /> 1525 Sherman Street,5`h Floor <br /> Denver, CO 80203 <br /> Re: The Board of County Commissioners of Pitkin County, et aL v. Mid-Continent <br /> Resources,Inc, et aL v. State of Colorado, et aL <br /> Pitkin County District Court Case No.97-CV-131-3 <br /> Dear Cheryl: <br /> I have now had an opportunity to review the Division of Mineral and Geology's <br /> responses to Mid-Continent Resources, Inc. and Creditors' Trustee's interrogatories and requests <br /> for production of documents directed to the State of Colorado, Department of Natural Resources <br /> Division of Minerals and Geology. I have a number of concerns regarding the Division's <br /> responses to these discovery requests. <br /> Interrogatory No. 6 requested an itemization by amount and date of all DMG and/or <br /> AML expenditures for revegetation of the north facing slope below the strip head above Mine <br /> No. 5. The response was just to state what ;the total cost was and a reference to a number of <br /> documents. I would like the itemization requested in Interrogatory No. 6. <br /> Interrogatory No. 7 asked for the identity of all documents concerning revegetation on the <br /> south facing slope below Mine No. 5 Fan Pad. The response was that the Division has made no <br /> attempt to revegetate that slope. However, Mid-Continent has observed and photographed <br /> revegetation activity in this area. Interrogatory No. 7 is not limited to revegetation attempts by <br /> only the Division, but encompasses any revegetation attempts. We would like to leave the <br /> information regarding that project. Alternatively, we may have to conclude that revegetation <br /> projects have been occurring in Coal Basin without the knowledge of the Division. <br /> Interrogatory No. 9 is directed towards reclamation of roads and I request that the <br /> Division answer it accordingly. <br />