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FROM :RGO NRT. RES. SECTION TO 1 303 2410336 1996.01-31 11:02 #OSO P.02/04 <br /> . D <br /> STAT <br /> O <br /> DINO <br /> C�A. NORTON STATE OF COL OFADO 1525 Sherman SteES tr-5th <br /> Attorney General en Sherman Street- 3 Floor <br /> X1EPAR'7f�'1�1'I'OF�'w Denver Colorado$0203 <br /> STEBI�N K ERRENBRACX Ptone(303) 866-4500 <br /> Cje;f Deputy Attorney General OF nicE OF THE ATT 1'Cry PAX (303)866-5691 <br /> TltrYoTw M. Tymnovicu January 30, 19 95 <br /> Solicitor General Y <br /> VIA FACSMILE <br /> Joel W. Cantriek <br /> Pendleton & Sabian, P.C. <br /> 303 East 17th Avenue <br /> Suite 1000 <br /> Denver, Colorado 80203-1263 <br /> R'l;: Di-yis-inn of Minerals and Geology v. Reeves. et al. <br /> Dear Joel: <br /> As you know, the so-day stay entered by the parties in -the <br /> above-cited case expires on February 3 , 1995- The Board is <br /> hesitant to ask the court for UZI, extension of that deadline. <br /> Therefore, we must move quickly on this matter. One or both of us <br /> will be available any time this week to meet with you ©n this. To <br /> further our discussion., this letter will address outstanding issues <br /> concerning a further stay of the case and better define the Board <br /> and Division' s position regarding this matter. <br /> on January 20, 1995, ' we faxed you a copy of the reclamati= <br /> schedule that the Division has constructed regarding complete <br /> reclamation of the Mid-Continent Resources mine site. The <br /> reclamation tasks set forth in the schedule are necessary to <br /> reclaim the site to applicable standards. These tasks are <br /> therefore a "must" for the Division. They, however, do not include <br /> unanticipated site conditions which may cause changes to the <br /> reclamation tasks. The Division would like your comment or <br /> response to the reclamation requirements and schedule. <br /> In our prior meetings, you have suggested that Mid-Continent <br /> Resources' liquidation plan requires that the Division and <br /> Resources negotiate a reclamation schedule and therefore Resources <br /> and. the Division should be the parties who negotiate a schedule. <br /> We disagree. <br /> Sections 4 . 3 . 1 . and 4.3 .2 of the liquidation plan mandates <br /> that the Mined Land Reclamation Board receive $3 million less <br /> certain amounts from the plan_ Section 4 .3.4 then provides that to <br /> the extent that liquidation funds are available, such funds: <br />