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PARCEL, MAURO, HULTIN & SPAANSTRA, P. C. <br /> Colorado Division of Minerals and Geology <br /> Mr. Larry P. Routten <br /> January 17, 1994 <br /> Page 2 <br /> disposition of the NOV could substantially affect the need for and/or scope of the hearing <br /> on the CO. Similarly, we note that the assessment conferences to be held for the COs <br /> themselves could result in a separate appeal to the Board. For these reasons, we would <br /> suggest that the Division and Board consider consolidating formal hearings on the COs with <br /> hearings on the proposed penalties (or assessment conference results as appropriate), and <br /> potential hearings with respect to the underlying NOW In this way the Division and Mid- <br /> Continent will conserve the resources of the Board and avoid unnecessary confusion. <br /> Given the current schedules of the various administrative processes described above, <br /> it would be impossible to hold a consolidated hearing in January. Therefore, please <br /> consider this to be a formal request on behalf of Mid-Continent to defer all of the requested <br /> hearings until at least the February Board meeting. If the Board should have any questions <br /> or concerns regarding the request for formal hearing on the COs, please call me or Jeff <br /> Schwarz. Thank you. <br /> Sincerely, <br /> PARCEL, MAURO, HULTIN & SPAANSTRA, P.C. <br /> Dean . Massey <br /> Jeffrey W. Schwarz <br /> Attorneys for Mid-Continent Resources, Inc. <br /> DRM:JWS/bap <br />