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BEFORE THE MINED LAND RECLAMATION BOARD, <br />SNOWCAP COAL COMPANY, INC.'S MOTION FOR EXTENSION OF TIME TO <br />SUPPLEMENT EXHIBITS WITH REBUTTAL EXPERT REPORTS, OR IN THE <br />ALTERNATIVE TO STRIKE FONTANARI EXHIBITS 24 AND 25 AND TO <br />PRECLUDE TESTIMONY <br />IN THE MATTER OF OBJECTIONS CONCERNING TECHNICAL REVISION NO. 69 <br />TO PERMIT NO. C-1981-041 <br />PERMITEE: SNOWCAP COAL COMPANY, INC. <br />Permittee, Snowcap Coal Company, Inc., a Delaware Corporation ("SCC"), provides <br />the following Motion for Extension of Time to Supplement Exhibits with Rebuttal Expert <br />Reports or In the Alternative to Strike Fontanari Exhibits 24 and 25 and to Preclude <br />Testimony as follows: <br />I. RELEVANT BACKGROUND <br />1. Consistent with the Requirements of Minor Revision No. 82 ("MR -82"), to Permit <br />No. C-1981-041 (the "Permit"), SCC submitted its repair and reclamation plan on <br />September 27, 2016, including a cost estimate. SCC's submission was part of an <br />application for a technical revision of the Permit on September 27, 2016, pursuant to <br />C.R.S. §34-33-116 and 2 CCR 407-2-2.08.4(2)("TR-69"). Those submissions <br />included reports and studies by J.E. Stover and Associates, ("Stover") Huddleston - <br />Berry Engineering and Testing LLC ("Huddleston -Berry"), and Fugro Consultants, <br />Inc. ("Fugro") <br />