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% 01/99 19:29 FAX 3037962777 BURNS FICA & 'WILL �b02 <br /> rky <br /> BURNS, FICA & WILL, P.C. <br /> ATrORPOM AT L^W <br /> PLA7A TOWER, SUITE 1 ozo <br /> ea00 SOUTH FIOOLERS GREEN CIRCLE <br /> E:NGLEWOOD, COLORADO 8Q i I I <br /> GEOFFREY P. ANDERSON April 1, 1999 TELrProne «oy) 7>3s-ze€e <br /> F-PUIP41LE (203) 796-2777 <br /> ENRECT tZOM 41 4--69@9 <br /> V]<A FACSYMU,E& FIRST CLMS MA L: <br /> (303)866-3555 <br /> Cheryl A.Lin im F-sq. <br /> O£fxce of the Attorney General <br /> Natural Resourow Section <br /> 1525 Sherman Street,5"Floor <br /> Denver,CO 80203 <br /> R.e: The Board of County Commissioners of Pitkin County, et aL v Mid-Continent <br /> Resoat ees,Ina,of al. Y.State of Colorado,of aL <br /> Pitkin County Mtrict Court-Case No-97-CV-131 .3 <br /> Dear Cheryl: <br /> I have now had an opportunity to review the Division of M4new acid Geology's <br /> responses to Mid-Continent Resowrces, Inc. and Creditors' Trustee's inten-ogatories and requests <br /> for production of documents directed to the State of Colorado, Departmew 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 /> Intx:rragatury No. 6 requestod an itemization by amount and date of all DMCr and/or <br /> AML expenditures for revegetation of the xxorth facing slope below the strip head above Mine <br /> No. 5. The response was just to state what the total cost was and a ret'ercam to a number of <br /> docwnents. 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 Mines No. 5 Fan Pad. The response was that the Division bas made no <br /> attempt to mvegetate that slope. However, Mid-Continent has observed and photographed <br /> revegetation activity in this area. Interrogatory No. 7 is not Iimited to revegetation attempts by <br /> only the Division, but encompasses any revegetation attempts. We would like to have the <br /> information regarding that prosect. Alternatively, we may 'have to conclude that revegetiation <br /> projects have been occurring irr Coal Basin without the knowledge of the Division. <br /> Interrogatory No. 9 is directed towards reclamat tin of roads and I request that the <br /> Division answer it accordingly, <br /> �0'd 95�:!2Z 66, 9 -1d13 8SSi99K0i:xPd <br />