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S fiQ Vr- , 4_;;� <br /> �;�-fir _ - <br /> 1261 <br /> CL <br /> DISTRICT COURT, PITKIN COUNTY, COLORADO <br /> Case No. 93 CV 201 <br /> DEFENDANTS' ANSWER TO PLAINTIFF' S COMPLAINT <br /> DIVISION OF MINERALS AND GEOLOGY, DEPARTMENT <br /> OF NATURAL RESOURCES, STATE OF COLORADO, <br /> Plaintiff, <br /> V. <br /> JOHN A REEVES; ROBERT DELANEY; <br /> DIAi:i DELANEY; AND MID-CONTINENT MINERALS CORPORATION, <br /> Defendants . <br /> John A. Reeves, Robert Delaney, Diane Delaney, and Mid- <br /> Continent Minerals Corporation (collectively "defendants" ) , by and <br /> through their counsel, Pendleton & Sabian, P.C. , answer the <br /> Amended Complaint (Complaint) as follows : <br /> 1 . As to the first sentence of ¶ 1 of the Complaint, the <br /> defendants admit that Mid-Continent Resources, Inc. (Resources) is <br /> a Delaware corporation and that it operated a complex of mines <br /> within Coal Basin, but deny that it operated a single coal mine <br /> known as "the Coal Basin Mine. " Such terminology as used here and <br /> elsewhere in the Complaint is inappropriate and therefore denied. <br /> The defendants admit the second sentence of said paragraph. <br /> 2 . As to the first sentence of ¶ 2 of the Complaint, the <br /> defendants admit that certain of Resources' operations are covered <br /> in part by mining and reclamation permit number C-81-017 . The <br /> second sentence of said paragraph contains allegations of law to <br /> which no responsive pleading is required. <br /> 3 . The first sentence of 1 3 of the Complaint contains <br /> allegations of law to which no responsive pleading is required. <br /> As to the second sentence of said paragraph, the defendants admit <br /> that Resources has filed several performance bonds and/or bond <br /> adjustments during the years of its operations, one of which in <br /> 1984 involved a deed of trust encumbering certain property in <br /> Garfield County. As to the third sentence of said paragraph, the <br /> defendants admit that John A. Reeves signed the deed of trust as <br /> President of Resources, but deny that he "personally obtained" the <br /> referenced. As to the fourth sentence of said paragraph, the <br /> defendants admit that two deeds of trust given in 1984 were <br /> released in 1989 upon substitution of a performance bond secured <br /> by a deed of trust on the rock dust plant tract . <br />