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~J <br /> <br /> <br />STATE OF COLORADO <br />BEFORE THE MINED LAND RECLAMATION BOARD <br />PERMIT NUMBER 77-141 <br />~!~~ s 1 1983 <br />L111JED !1~P;p RESIAhf.hilON O!'JISIO`1 <br />Cefo. Uepi. of IJa!url ilos;,urces <br />COMPLAINT OF LANDOWNER AGAINST ANDESITE ROCK COIdPANY PURSUANT TO SECTIONS <br />24-4-104(5) and 34-32-124, CRS 1973 (as amended). <br />HALLYN F. HALL, <br />Landowner, <br />vs. <br />ANDESITE ROCK COMPANY, <br /> <br />Operator. <br />COMES NOW the landowner, Hallyn F. Hall, by and through his attorney, <br />Karl F. Kumli, III, and for his Complaint, states as follows: <br />1. Mr. Hall is the owner of land in Boulder County, Colorado which <br />includes the property upon which the operator, Andesite Rock Company <br />("Andesite") conducts mining operations; specifically, the E 1/2 of the E 1/2 <br />of Section 26 and the W 1/2 of the W 1/2 of Section 25, Township 3 North, <br />Range 71 West of the 6th PM ("land"). <br />1973. <br />2. Andesite entered onto the land under a lease dated February 1, <br />3. On November 19, 1981, the Mined Land Reclamation Board issued a <br />"life of the mine" permit to Andesite "in reliance upon the representations <br />and promises made in such application Lfor a permit]. <br />I. NOTICE <br />4. In its application Andesite represented, by letter of Mr. George <br />C. Baker of November 18, 1981, a copy of which is attached and incorporated <br />-1- <br />