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Chemical Waste Management, Inc., Houston, Texas
Coast Rock Products, Inc., Santa Maria, California
Earth Island Institute, San Francisco, California
Haseko (Hawaii), Inc., Oahu, Hawaii

Homestake Mining Company, San Francisco, California
Independence Mining Company, Denver, Colorado

The Irvin Company, Newport Beach, California
Kaiser Hospital, Inc., Oakland, California

MDI Guam, Inc., Agana, Guam

Mitsui & Co., Ltd., New York, New York

Newhall Land and Farming Company, Valencia, California

Oakland Scavenger Company, Oakland, California
Partin Limestone Products, Inc., Riverside, California
City of Pinole, California, Pinole, California
City of Richmond, California, Richmond, California
Rail-Cycle Partnership, Los Angeles, California
Riverside Cement Company, Riverside, California
Salmon Trollers Association, Fort Bragg, California
City of San Diego, California, San Diego, California
Shapell Industries, Milpitas, California

Legal Services

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Southern Pacific Milling Company, Oxnard, California
Sumitomo Construction Compa~

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Legal Services

Yona, Guam

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ROBERT JAY URAM
(December 16, 1993)

Response to No. 17:

In 1991, I failed to file a return for the City of Columbus, Ohio due to a mistake by my accountant. The filing was required due to income from a limited partnership we own there. Upon being notified of the error, the return was filed,. I paid income tax to the City of Columbus in the amount of $33.00. My accountant paid the late interest of $7.00.

For 1992, Form 1040, I paid a $707.00 penalty for underpayment of estimated tax. Underpayment due to change in McCutchen, Doyle, Brown & Enersen fiscal year. Also in 1992, paid penalties for untimely payment and filing federal employment tax for household workers for period from September 30, 1988 to March 1993 in the total amount of $455.22.

For my 1990 Federal Income Tax Return, I paid a penalty and interest of $419.39. The payment was caused by a bank error. The bank incorrectly negotiated a payment of $17,321.00 to the Internal Revenue Service as a payment of $1,732.00. This resulted in the assessment of a late penalty and interest for "underpayment".

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The enclosed financial disclosure report (Enclosure I) filed by Robert J. Uram for the position of Director, has been reviewed in compliance with 5 CFR 2634.605. In addition to the standard conflict of interest prohibitions contained in 18 U.S.C. Sections 201-209 and Executive Order 12674 (as modified by E.0. 12731), the Director, Office of Surface Mining Reclamation and Enforcement, is also subject to five statutory prohibitions that apply to employees in our Department.

These five statutory prohibitions, commonly referred to as "Organic Act" prohibitions, are: 18 U.S.C. 437; 30 U.S.C. 6; 30 U.S.C. 1211(f); 43 U.S.C. 11 and 43 U.S.C. 31(a). Except for 30 U.S.C. 1211(f), the provisions of each of these organic acts are extended to the Director, Office of Surface Mining Reclamation and Enforcement, by Department of the Interior regulations in 43 CFR Part 20.

Upon confirmation as Director, Office of Surface Mining Reclamation and Enforcement, Mr. Uram will terminate his partnership with the law firm of McCutchen, Doyle, Brown & Enersen (the firm). Mr. Uram will take a leave of absence from the firm effective January 1, 1994. Upon termination from the firm, Mr. Uram will receive payment of his capital account contribution, a return of his contribution to a risk management fund and his share of partnership profits through December 31, 1993. Mr. Uram will not receive a severance payment.

Mr. Uram has a self directed Section 401 K plan with the firm. This pension plan is managed by the United Missouri Bank. The firm does not make any contributions to the plan on his behalf and will not make any contributions to the account after he leaves the firm. Mr. Uram's interest in this pension plan investment is allowed by the conflict of interest provisions that apply to the Director, Office of Surface Mining Reclamation & Enforcement.

Our review of Department records and Mr. Uram's review of the firm's records revealed specific cases or issues involving the

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