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21. The Division admits that the liquidation plan refers to distributions to be made <br />by the Creditors' Trustee for reclamation purposes and states that the plan speaks for itself. <br />The Division states, however, that the liquidation plan sets forth more details and <br />requirements regarding amounts to be taken against reclamation funds than those set forth in <br />the allegations of paragraph 21. To the extent that the allegations contained in paragraph 21 <br />incorporate legal argument, including but not limited to, use of the phrase "The effect of the <br />Plan is to "cap" or set a maximum amount owed by the Creditors' Trust to DMG for Coal <br />Basin mine property reclamation," no admission or denial is required. <br />22. The Division admits that the liquidation plan refers to "Reclamation Bond" and <br />states that the plan speaks for itself. <br />FIRST CLAIM FOR RELIEF <br />(Injunction) <br />23. The Division incorporates all of its previous responses in this Answer as if set <br />forth in full. <br />24. The Division has insufficient knowledge or information regarding the truth or <br />veracity of the allegations in paragraph 24 and therefore denies the same. <br />25. The Division admits that at present time the reclamation plan requires demolition <br />of the Lamp house, its power lines, a metal building near the former Preparation Plant, and a <br />water tank. As to "access roadways," the Division is without sufficient knowledge or <br />information regarding the meaning of the term "access roadways" so as to form a belief as to <br />the truth or veracity of that part of the allegation and therefore denies the same. As to <br />culverts for stream crossings, the Division will remove some of the culverts, but will leave <br />others in place. The Division is without sufficient knowledge or information regarding the <br />truth or veracity of the allegation that all of the "improvements" are located on property <br />currently owned by MidCon Realty, LLC and therefore denies the same. <br />26. The Division has insufficient information or knowledge to form a belief as to the <br />truth or veracity of the allegations of paragraph 49 and therefore denies the same. <br />27. The Division admits that Robert Delaney sent a letter dated June 22, 1998, to <br />Mike Long in which he mentions that it was expected that a number of post - mining land uses <br />will be developed on the remaining private land in Coal Basin and that in this regard he states <br />that "most of the remaining improvements and facilities will be needed and useful for these <br />post - mining uses." Mr. Delaney specifically names the Lamphouse, power line leading to <br />4 <br />