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i• <br /> <br />~II ~I~II~'I~~~~~ ~I~ <br />sss <br />UNITED STATES BANKRUPTCY COURT <br />FOR THE EASTERN DISTRICT OF KENTUCKY <br />(LEXINGTON DIVISION) <br />In re: ) Bankruptcy No. 00- <br />51374 and 00-51376 <br />QUAKER COAL COMPANY, IAIC., et al., ) through 00-51399 <br />Debtor. ) (Chapter 11) <br />Jointly <br />Administered <br />COLORADO DIVISION OF MINERALS AND GEOLOGY'S OBJECTION TO THE <br />LENDERS' MOTION FOR ADEQUATE PROTECTION AND FOR RELIEF FROM <br />STAY WITH RESPECT TO THE PROCEEDS OF THE SALE OF POWDERHORN <br />COAL COMPANY'S MACHINERY AND EQUIPMENT IN COLORADO <br />COMES NOW Creditor Colorado Division of Minerals and <br />Geology, by and through its attorneys, Colorado Attorney <br />General Ken Salazar and Assistant Attorney General Robert D. <br />Clark, and, for its Objection to the Lenders' Motion for <br />Adequate Protection And for Relief From Stay With Respect to <br />the Proceeds of the Sale of Powderhorn Coal Company's <br />Machinery and Equipment In Colorado, states as follows: <br />INTRODUCTION <br />Until approximately a year ago, the Debtor Powderhorn <br />Coal Company operated an underground coal mine near Palisade, <br />Colorado under Permit No. C-81-091 (the "Permit"), issued to <br />pouderhorn coal/objection to lenders' adequate protection motion <br />