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17. Diane Delaney was charged with the responsibility for <br />protecting society and the environment from the adverse effects <br />of the coal mining operation. <br />18. At all times relevant herein, Diane Delaney was an <br />agent of Resources for purposes of § 34 -33- 123(12), C.R.S. <br />(1984 & 1993 Supp.). <br />19. Robert Delaney has acted as a spokesperson for <br />Resources in its dealings with the Division, and has met with the <br />Division to discuss reclamation requirements at the Coal Basin <br />Mine. <br />20. Robert Delaney is the Executive Vice President and <br />Corporate Counsel of Resources. <br />21. At all times relevant herein, Robert Delaney was an <br />agent of Resources for purposes of § 34 -33- 123(12), C.R.S. <br />(1984 & 1993 Supp.). <br />22. John A. Reeves has acted as a spokesperson for <br />Resources in its dealings with the Division, and has met with the <br />Division to discuss reclamation requirements at the Coal Basin <br />Mine. <br />23. John A. Reeves is the President of Resources. <br />24. John A. Reeves and Robert Delaney, either jointly or <br />individually, were charged with the responsibility of making the <br />day -to -day decisions regarding the conduct of corporate business. <br />25. John A. Reeves was charged with responsibility for the <br />operation of all or a part of the Coal Basin Mine. <br />26. At all times relevant herein, John A. Reeves was an <br />agent of Resources for purposes of § 34- 33- 123(12), C.R.S. <br />(1984 & 1993 Supp.). <br />27. Minerals wholly owns Resources. The Board of Direc- <br />tors of Minerals made decisions about the operation and expendi- <br />tures of Resources. <br />28. Minerals and Resources, as co- obligors, borrowed sub- <br />stantial sums of money used by Resources for its mining oper- <br />ation. <br />29. Minerals was responsible for the operation of all or <br />part of the mine. <br />-4- <br />