EXHIBIT 25.2


                       SECURITIES AND EXCHANGE COMMISSION
                            Washington, D.C.  20549

                           ---------------------------

                                    FORM T-1

                            STATEMENT OF ELIGIBILITY
                   UNDER THE TRUST INDENTURE ACT OF 1939 OF A
                    CORPORATION DESIGNATED TO ACT AS TRUSTEE

         Check if an application to determine eligibility of a Trustee
                         pursuant to Section 305 (b)(2)


                           ---------------------------

                                 CITIBANK, N.A.
              (Exact name of trustee as specified in its charter)

                                             13-5266470
                                             (I.R.S. employer
                                             identification no.)

399 Park Avenue, New York, New York          10043
(Address of principal executive office)      (Zip Code)

                           ---------------------------

 NEWMONT MINING CORPORATION                  NEWMONT USA LIMITED
              (Exact name of obligor as specified in its charter)
   DELAWARE                                     DELAWARE
         (State or other jurisdiction of incorporation or organization)
   84-1611629                                   13-2526632
                     (I.R.S employer identification number)
1700 Lincoln Street                          1700 Lincoln Street
Denver, Colorado 80203                       Denver, Colorado 80203
                    (Address of principal executive offices)

                           ---------------------------

                     Subordinated Guaranteed Debt Securities
                      (Title of the indenture securities)
<PAGE>

Item 1.   General Information.

               Furnish the following information as to the trustee:

          (a)  Name and address of each examining or supervising authority to
               which it is subject.

               Name                                           Address
               ----                                           -------
               Comptroller of the Currency                    Washington, D.C.

               Federal Reserve Bank of New York               New York, NY
               33 Liberty Street
               New York, NY

               Federal Deposit Insurance Corporation          Washington, D.C.

          (b)  Whether it is authorized to exercise corporate trust powers.

               Yes.

Item 2.   Affiliations with Obligor.

               If the obligor is an affiliate of the trustee, describe each such
               affiliation.

                    None.

Item 16.  List of Exhibits.

          List below all exhibits filed as a part of this Statement of
          Eligibility.

          Exhibits identified in parentheses below, on file with the Commission,
          are incorporated herein by reference as exhibits hereto.

          Exhibit 1 - Copy of Articles of Association of the Trustee, as now in
          effect. (Exhibit 1 to T-1 to Registration Statement No. 2-79983)

          Exhibit 2 - Copy of certificate of authority of the Trustee to
          commence business. (Exhibit 2 to T-1 to Registration Statement No.
          2-29577).

          Exhibit 3 - Copy of authorization of the Trustee to exercise corporate
          trust powers. (Exhibit 3 to T-1 to Registration Statement No. 2-55519)

          Exhibit 4 - Copy of existing By-Laws of the Trustee. (Exhibit 4 to T-1
          to Registration Statement No. 33-34988)

          Exhibit 5 - Not applicable.

<PAGE>

          Exhibit 6 - The consent of the Trustee required by Section 321(b) of
          the Trust Indenture Act of 1939. (Exhibit 6 to T-1 to Registration
          Statement No. 33-19227.)

          Exhibit 7 - Copy of the latest Report of Condition of Citibank, N.A.
          (as of December 31, 2004 - attached)

          Exhibit 8 - Not applicable.

          Exhibit 9 - Not applicable.

                               ------------------


                                   SIGNATURE

     Pursuant to the requirements of the Trust Indenture Act of 1939, the
Trustee, Citibank, N.A., a national banking association organized and existing
under the laws of the United States of America, has duly caused this statement
of eligibility to be signed on its behalf by the undersigned, thereunto duly
authorized, all in The City of New York and State of New York, on the 12th day
of May, 2005.



                                  CITIBANK, N.A.

                                  By  /s/ John J. Byrnes
                                      --------------------------
                                      John J. Byrnes
                                      Vice President



<PAGE>

Charter No. 1461
Comptroller of the Currency
Northeastern District
REPORT OF CONDITION
CONSOLIDATING
DOMESTIC AND FOREIGN
SUBSIDIARIES OF
Citibank, N.A. of New York in the State of New York, at the close of business on
December 31 2004, published in response to call made by Comptroller of the
Currency, under Title 12, United States Code, Section 161. Charter Number 1461
Comptroller of the Currency Northeastern District.

ASSETS                                      Thousands of dollars
Cash and balances due from
     depository institutions:
Noninterest-bearing balances
     and currency and coin ................       $13,354,000
Interest-bearing balances..................        21,756,000
Held-to-maturity securities................            47,000
Available-for-sale securities .............       105,096,000
Federal funds sold in domestic
     Offices                                        4,622,000
Federal funds sold and
     securities purchased under
     agreements to resell..................        11,015,000
Loans and leases held for sale.............         3,580,000
Loans and lease financing
     receivables:
     Loans and Leases, net of
     unearned income.......................       378,100,000
LESS: Allowance for loan and lease
     losses ...............................         7,897,000
Loans and leases, net of unearned
     income, allowance, and reserve........       370,203,000
Trading assets.............................        97,697,000
Premises and fixed assets
     (including capitalized leases)........         4,359,000
Other real estate owned....................            72,000
Investments in unconsolidated
     subsidiaries and associated
     companies.............................         1,034,000
Customers' liability to this bank
     on acceptances outstanding............         1,206,000
Intangible assets: Goodwill................         9,593,000
Intangible assets: Other intangible
      assets...............................        10,557,000
Other assets...............................        40,338,000
                                                 ------------
TOTAL ASSETS...............................      $694,529,000
                                                 ============

LIABILITIES
Deposits: In domestic offices..............      $124,428,000
Noninterest- bearing.......................        22,303,000
Interest- bearing..........................       102,125,000
In foreign offices, Edge and
     Agreement subsidiaries,
     and IBFs..............................       334,574,000
Noninterest- bearing.......................        24,540,000
Interest- bearing..........................       310,034,000
Federal funds purchased in domestic
     Offices                                       12,799,000
Federal funds purchased and securities
     sold under agreements
     to repurchase.........................         8,626,000

<PAGE>

Demand notes issued to the
     U.S. Treasury.........................                 0
Trading liabilities........................        56,630,000
Other borrowed money (includes
     mortgage indebtedness and
     obligations under capitalized
     leases): ss...........................        52,870,000
Bank's liability on acceptances
     executed and outstanding..............         1,206,000
Subordinated notes and debentures..........        13,903,000
Other liabilities..........................        34,852,000
                                                   ----------
TOTAL LIABILITIES..........................      $639,888,000
                                                 ------------
Minority interest in consolidated
Subsidiaries...............................           500,000

EQUITY CAPITAL
Perpetual preferred stock and
     related surplus.......................         1,950,000
Common stock ..............................           751,000
Surplus....................................        25,972,000
Retained Earnings..........................        25,935,000
                                                   ----------
Accumulated net gains (losses)
     on cash flow hedges...................        -  467,000
Other equity capital components............                 0
                                                   ----------
TOTAL EQUITY CAPITAL.......................       $54,141,000
                                                  -----------
TOTAL LIABILITIES AND EQUITY
     CAPITAL ..............................      $694,529,000
                                                 ============

I, William J. Gonska, Controller & Vice President of the above-named bank do
hereby declare that this Report of Condition is true and correct to the best of
my knowledge and belief.
William J. Gonska, CONTROLLER & VICE PRESIDENT

We, the undersigned directors, attest to the correctness of this Report of
Condition. We declare that it has been examined by us, and to the best of our
knowledge and belief has been prepared in conformance with the instructions and
is true and correct.
ALAN S. MACDONALD
WILLIAM R. RHODES
ROBERT B. WILLUMSTAD
DIRECTORS