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1999-04-06_GENERAL DOCUMENTS - C1981017 (2)
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1999-04-06_GENERAL DOCUMENTS - C1981017 (2)
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Last modified
3/17/2021 6:45:47 AM
Creation date
5/3/2012 9:33:37 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
4/6/1999
Doc Name
Response to DMG's interrogatories
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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will exhaust all funds available to it under the Bankruptcy Liquidation Plan before completing all <br /> reclamation. <br /> ANSWER NO. 9: Among others, DMG's "accounting" dated January 22, 1998, as <br /> revised February 3, 1998, Deposition of Steven G. Renner taken March 1, 1995, letter from <br /> Cheryl Linden to Joel Cantrick dated January 31, 1995, Exhibit 131 from DMG v. Reeves, et al., <br /> Pitkin County District Court, Case No. 93-CV-201. <br /> INTERROGATORY NO. 10: Identify each document referred to or relied upon to <br /> respond to the above Interrogatory no. 9. <br /> ANSWER NO. 10: See response to Interrogatory No. 9, above. <br /> INTERROGATORY NO. 11: State the factual and/or legal basis for the LLC's <br /> allegation, pleading, statement, belief, or contention in paragraph 39 of the LLC's complaint that <br /> some of the reclamation that DMG performed on the LLC's property has been substandard and in <br /> breach of the reclamation plan's requirements. Include in your response the specific reclamation <br /> tasks which are alleged to be in violation of the reclamation plan and/or were substandard; for <br /> each reclamation task you allege is substandard and/or in violation of the reclamation plan, cite <br /> the specific portion of the reclamation plan upon which you relied or referred in responding to <br /> this interrogatory or which relates to the reclamation task alleged to be in violation of the plan <br /> and/or substandard; for each reclamation task, state the basis for your allegation that the task is in <br /> violation of the reclamation plan; state the definition of "substandard" used in making this <br /> allegation; and as to each task alleged to be substandard, each methodology used and actually <br /> applied in making the determination that a reclamation task was substandard. <br /> ANSWER NO. 11: Some of the contouring of the ground above the road between the <br /> Prep Plant site and the rock tunnel entrance was done improperly so that even though the area <br /> was on a mild grade, a large slump and erosion occurred. Overall, the revegation practices <br /> employed by CDMG in their standard 20.0 construction performance standard for revegetation <br /> do not correspond with the approved reclamation plan. Backfilling of the highwall at the rock <br /> tunnel area was not undertaken to the standards of the Reclamation Plan. It is questionable <br /> whether the Dutch Creek diversion and the reshaping of the old refuse pile (Huntsman project) <br /> were conducted with prudent reclamation practices in mind. <br /> INTERROGATORY NO. 12: Identify each document referred to or relied upon in <br /> responding to the above Interrogatory no. 11. <br /> ANSWER NO. 12: See response to Interrogatory No. 11, above. <br /> INTERROGATORY NO. 13: State the factual and/or legal basis for the allegation in <br /> paragraph 40 of the LLC's complaint that the LLC has been damaged by DMG's failure to <br /> comply with the reclamation plan for reclamation already performed on the LLC's property. <br /> Include in your response an identification of each reclamation task the LLC is alleging was in <br /> violation of the reclamation plan and for each reclamation task, identify the specific portion of <br /> 5 <br />
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