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1999-04-06_GENERAL DOCUMENTS - C1981017
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1999-04-06_GENERAL DOCUMENTS - C1981017
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Last modified
3/16/2021 7:34:00 PM
Creation date
5/3/2012 9:33:35 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
4/6/1999
Doc Name
Trustee under bankruptcy plan of liquidation answers
From
US District Court
To
Mid-Continent Resources, Inc. & DMG
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
Tags
DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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INTERROGATORY NO. 9: Identify requests for proposals or bids regarding <br />reclamation work to be done at the Coal Basin mine site by the Division received from any <br />source by the Creditors' Trustee, MCR or its agents or principals, or about which the Creditors' <br />Trustee and/or MCR, its agents or principals had knowledge. Include in your response the <br />specific request for proposal or bid received or known by the Trustee and/or MCR, its agents or <br />principals, if a request or bid is known by the Trustee and/or MCR, the extent and date of that <br />knowledge, the date of the request or bid, and the reclamation proposed in the bid or request. <br />ANSWER NO. 9: MCR has requested production of all such bids from DMG and <br />therefore, MCR should have copies of or should have had the opportunity to copy all such <br />requests for proposals or bids regarding reclamation work in Coal Basin. <br />INTERROGATORY NO. 10: State the factual and/or legal basis for third -party <br />plaintiffs' allegation, pleading, statement, belief, or contention in paragraph 25 of the Amended <br />Third -Party Complaint that the information provided to MCR and the Trustee by the Division in <br />response to their request for an accounting "lacks sufficient detail for Defendants to determine <br />the true status of funding and reclamation." Include in your response the specific information the <br />third -party plaintiffs believe is lacking with regard to the Division's Accounting. <br />ANSWER NO. 10: The principal problem with the accounting furnished by DMG is the <br />fact that the accounting does not provide categories that correlate with the categories in the <br />Reclamation Plan and the calculations made by DMG in connection with arriving at the amount <br />of bonding for the Plan, nor does it adequately describe work that DMG performed. <br />INTERROGATORY NO. 11: Did MCR or any other entity submit a reclamation plan <br />to the bankruptcy court which presided over MCR's bankruptcy proceeding in conjunction with <br />the liquidation plan which was ultimately confirmed by that court? <br />ANSWER NO. 11: The Debtor's Second Amended Plan of Liquidation, which was <br />approved by the Bankruptcy Court, and for which MLRB and DMG voted, specifically defines <br />the Reclamation Plan at ¶ 1.32 as meaning MLRB permit C -81 -017, submitted as required by the <br />Colorado Mined Land Reclamation Act, C.R.S. Title 34, Article 33. This document was thus <br />incorporated by reference. <br />INTERROGATORY NO. 12: In paragraph 29 of the Amended Third -Party Complaint, <br />MCR and the Trustee allege that there exists "a contract entered into by, among others, DMG, <br />MCR and MCR's creditors who are all parties to and bound by the Liquidation Plan." Given this <br />allegation, does MCR and/or the Trustee intend to seek the consent of all those bound by the <br />alleged contract or Liquidation Plan as to any changes in reclamation to be done at the Coal <br />Basin site which may occur as a result of the present lawsuit? Include in your response the <br />specific basis for your answer. <br />ANSWER NO. 12: Objection, calls for a legal conclusion. <br />INTERROGATORY NO. 13: State whether MCR and/or the Trustee believes that the <br />reclamation plan required by MCR's permit defines or sets forth the specific mechanics of how <br />7 <br />
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