_GENERAL DOCUMENTS - C1981017 (142)

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OFFICE OF GENERAL COUNSEL MID-CONTINENT RESOURCES, INC. P.O.DRAWER 790 818 COLORADO AVENUE CHICAGO OFFICE GLENWOOD SPRINGS,COLORADO 81602 TELEPHONE 625 PLAINFIELD ROAD AREA CODE 303 WILLOWBROOK,IL 60821 94"5" September 6, 1985 REGE0VE SEP 9 Mr. Robert A. Hykan Assistant Attorney General MINED LAND Natural Resources Section RECLAMATION DIVISION State Services Building 1525 Sherman Street Denver, CO 80203 Mr. David C. Shelton Director Mined Land Reclamation Division 423 Centennial Building 1313 Sherman Street Denver, CO 80203 Dear Mr. Hykan and Mr. Shelton: Pursuant to prior discussions , Mr. Hykan sent me proposed Stipulation in settlement of the Show Cause Order pending before the MLRB and set for hearing on September 24 . Dave Sturges and I have reviewed the draft care- fully and enclose herewith a proposed re-draft. We feel that it is important that the Stipulation and accompanying exhibits when presented to the Board will fairly present the Division' s side of the matter, and also present Mid-Continent' s side of _the matter, including mitigative efforts, all directed to consideration of the basis on which the Stipulation was reached. On the basis of settlement by stipulation, we respectfully urge Mr. Shelton to withdraw the first pattern determination of the Show Cause Order covering the two topsoil NoVs, and also to withdraw those citations in which a no fault determination was made. It is our feeling that where the Division has made such determination, no basis exists on which they should be considered as "un- warranted" . We have drafted this Stipulation on the basis of such withdrawals. I have included language that I believe effectively shuts down the operation with the exception of those items