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BY HAND DELIVERY <br />Larry P. Routten <br />Senior Reclamation Specialist <br />Colorado Department of Natural Resources <br />Division of Minerals and Geology <br />1313 Sherman Street <br />Denver, Colorado 80203 <br />Dear Mr. Routten: <br />PARCEL, MAURO, HULTIN & SPAANSTRA, P. C. <br />ATTORNEYS AT LAW <br />SUITE 3600 <br />1801 CALIFORNIA STREET <br />DENVER, COLORADO 80202 <br />TELEPHONE (303) 292 - 6400 <br />TELECOPIER (303) 295 - 3040 <br />December 20, 1993 <br />199 <br />Re: Mid - Continent Resources, Notice of Violation ( "NOV ") C -93 -130 <br />This letter is submitted on behalf of Mid - Continent Resources ( "Mid- Continent ") by <br />Parcel, Mauro, Hultin & Spaanstra, P.C. in its capacity as special environmental counsel to <br />Mid - Continent. We have been retained by Mid - Continent and our approval as special <br />environmental counsel is currently pending before the United States District Court in Bankruptcy <br />for the District of Colorado. Sep In re Mid - Continent Resources. Inc., Case No. 92 11658 <br />PAC. <br />Attached to this letter is a submittal that addresses requirements imposed by the Division <br />of Minerals and Geology ( "Division ") on Mid - Continent in NOV C -93 -130, issued on September <br />29, 1993, and modifications to that NOV issued by the Division on October 4, 1993. This <br />submittal does not concede issues of law or fact surrounding the issuance of the NOV and the <br />modification. Mid - Continent reserves the right to contest all such issues of law and fact, which <br />include, but may not be limited to: (1) the Division's authority to assert jurisdiction over so- <br />called "pre -law" areas at Mines 1, 2, 3, and 4 not affected by mining activity since prior to <br />passage of the federal Surface Mining Control and Reclamation Act ( "SMCRA ") of 1977; and <br />(2) the propriety of issuing an NOV and seeking minor and /or technical revisions to a <br />reclamation plan more than a year after the August, 1992 revocation of Permit No. C -81 -017 <br />and subsequent to the September 22, 1993 revocation of Mid - Continent's reclamation bond by <br />the Mined Land Reclamation Board ( "MLRB "). <br />