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Mr. Congdon filed his first Location Certificate on the White Banks Claims in <br /> 1982. (See Exhibit 238). <br /> In August of 1986, Mr. Congdon filed a Plan of Operation for the White Banks <br /> Mines. (See Exhibit 203). <br /> In May of 1987, Robert Congdon and Julie Otis jointly filed location 'certificates <br /> for the White Banks Mines labeled as 2, 3, 4, 5 and 6. These were an expansion of the <br /> original White Banks Mines. (See Exhibit 240). <br /> In May of 1991, Mr. Congdon filed location certificates for the ten White Banks <br /> Claims. (See Exhibit 242). <br /> Additional location certificates were filed on the White Banks Claims in Mr. <br /> Congdon's name in August of 1991. (See Exhibit 206). Mr. Congdon doesn't remember <br /> why his wife's name was not on any of these location certificates. <br /> In 1991, Mr. Congdon was cutting the stone with a chain saw. He was operating <br /> without a permit. He was red tagged by Pitkin County which he ignored. Eventually, <br /> Pitkin County sued him. The litigation lasted for the next nine years which was <br /> frustrating for Mr. Congdon because he couldn't get into production. Mr. Congdon <br /> finally obtained approval from Pitkin County in 1998. (See exhibit 204). <br /> Ms. Skinner and Mr. Congdon divorced in July of 1994. Pursuant to the divorce <br /> decree, Ms. Skinner relinquished her ownership share of the White Banks Claims to Mr. <br /> Congdon. Mr. Congdon received 90% of the White Banks claims. In the divorce <br /> decree, Mr. Congdon agreed to transfer a 5% ownership interest to each of their two <br /> children, Nicholas Congdon and Maree Love Congdon. (See Exhibit 2). <br /> 3 <br />