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~IIIII'I~II~~II~II~ sss MARCH, MYATT, KORB, CARROLL & BRANDES ATTORNEYS AND COUNSELLORS AT LAW ROBERTSON BVILDING 110 EAST OaK STREET ARTHUR E. MgRC H, JR. RAM6EY D. MrgTT FORT COLLINS, COLORADO 80524 MARn L. nORB (303) 482-4322 JOSEPH T. CARROLL,JR. ROBERT W. GRANDE S, JR. RICHARD 6.GAST May 13, 1987 LUCIA A. LIL EY J. BRADFORD MARCH Mr. David Barry Reclamation Specialist Colorado Mined Land ]declamation Division 423 Centennial Building 1313 Sherman Street Denver, CO 80203 Dear Mr. Barry: ARTHUR E. MARCH 1909-196 M OILING 40DRE55~ P. O. BOx 469 FORT COLLIN S, CO 80522 ~~~~~ ~~ td AY 141997 MINED ~'N~ ISION DECLAMATION D Enclosed is a copy of the Notice regarding your deposition to be taken on Wednesday, May 20, 1987 at 1:30 p.m. at your office. Please have your file on the G.L. gravel pit available at that time. I would like to meet with you at 1:00 p.m. to discuss the deposition and briefly review the file. This should enable us to save some time during the deposition. By way of background on the deposition, Glass Livestock, d/b/a G.L. Gravel, i:; currently involved in its second Chapter 11 proceeding. In conjunction with the bankruptcy, G.L. Gravel has filed a Complaint against the Bank asserting that when it fore- closed on the gravel pit, it did not bid in the reasonable value of the pit. G.L. Gravel is asserting that at the time of the foreclosure sale, which was in February, 1986, the gravel pit was fully operational. The thrust of the deposition will be to deter- mine the nature, scope and extent of the regulatory violations for the G.L. gravel pit in 1985 and early 1986. The case is set for trial on June 9, 1987. This deposition is being taken in lieu of your live testimony at trial because it is my understanding you will be out of town on June 9th. The Court will allow us to use your deposition in lieu of live testi- mony if you will be more than 100 miles from Denver on the 9th. I will have you testify to this fact at the beginning of the deposi- tion. If you have any questions about this matter prior to the deposition, don't hesitate to give me a call.