1994-01-06_ENFORCEMENT - C1981017

• Permit No: C1981017
• IBM Index Class Name: Enforcement
• Doc Date: 1/6/1994
• Doc Name: Bid Documents ‎(IMP)‎ CV-93-86,89,94,98 &106
• Violation No.: C-93-86, C-93-89, C-93-94, C-93-98, C-106
• Media Type: D
• Archive: No

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PARCEL, M-AURO, HULTIN & SPAANSTPA, P. C.
ATTORNEYS AT LAW
SUITE 3600
IHOI CALIFORNIA STREET
DENVER.COLORADO 60202-2636
TELEPHONE[phone]
TELECOPIER(303)295-3040
January 6, 1994
BY HAND DELIVERY
Ms. Sandra L. Brown, Conference Officer
Colorado Department of Natural Resources
Division of Minerals and Geology
1313 Sherman Street
Denver, Colorado 80203
Re: Mid-Continent Resources, Inc. - Settlement Agreements
Associated with Notices of Violation ("NOV") C-93-086,
C-93-089, C-93-094, C-93-98 and amwo
Dear Ms. Brown:
Attached to this cover letter are executed settlement
agreements for Notices of Violation C-93-086, C-93-089, C-93-094,
C-93-98 and C-93-106 issued by the Division to Mid-Continent
Resources, Inc. As you know, the operator is the subject of
proceedings pursuant to Chapter 11 of the United States Bankruptcy
Code. I have been advised by the operator's bankruptcy counsel
that the automatic stay provisions of the Bankruptcy Code enjoin
the enforcement of a money judgement obtained in a proceeding to
enforce state regulatory powers. Paragraph 2 of the Settlement
Agreement therefore should provide that "The penalty shall be paid
to the Division by the operator not later than 30 days from the
date thereof subject to any applicable provisions of the U.S.
Bankruptcy Code." Because of the pending bankruptcy, we do not
believe that payment of the penalty will in fact be made within 30
days. Finally, please note that Diane Delaney has signed the
Settlement Agreements on behalf of Mid-Continent Resources, Inc. as
debtor in possession pursuant to Chapter 11 of the United States
Bankruptcy Code.
Sincerely,
PARCEL, MAURO, HULTIN & SPAANSTRA, P.C.
1
Dean R. Massey
Jeffrey W. Sc arz
Enclosures
cc: James B. Holden, Esq.