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DISTRICT COURT, PITKIN COUNTY, COLORADO <br /> Case No. 93CV201 <br /> PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT <br /> DIVISION OF MINERALS AND GEOLOGY, DEPARTMENT OF NATURAL <br /> RESOURCES, STATE OF COLORADO, <br /> Plaintiff, <br /> v. <br /> JOHN A. REEVES; ROBERT DELANEY ; DIANE DELANEY; AND MID-CONTINENT <br /> MINERALS CORPORATION, <br /> Defendants. <br /> The Plaintiff, Division of Minerals and Geology <br /> ( "Division" ) , through the Colorado Attorney General's Office, <br /> responds as follows to Defendants' Motion for Summary Judgment: <br /> I . INTRODUCTORY STATEMENT <br /> The defendants have previously filed a Motion to Dismiss. <br /> In response to that motion, the plaintiff filed a brief which <br /> included a statement of fact_ The Division hereby incorporates <br /> the facts recited in its response to the Motion to Dismiss. <br /> Additional facts will be referred to as is necessary to respond <br /> to the present Motion for Summary Judgment. <br />