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PERMFILE43364
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PERMFILE43364
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Last modified
8/24/2016 10:45:50 PM
Creation date
11/20/2007 11:33:10 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2005080
IBM Index Class Name
Permit File
Doc Date
8/16/2006
Doc Name
Opposition to Objectors Motion
From
Attorneys for Allen
To
DRMS
Media Type
D
Archive
No
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proportionate share of the net profits of such mining operations." This is along-recognized <br />principal of law in Colorado. See, e.g., Wolf v. Childs, 94 P. 292, 294 (Colo. 1908) (holding that <br />where first cotenant extracted mineral resources without consent of second cotenant, first <br />cotenant was still entitled to retain the proceeds of the resources he extracted, and <br />acknowledging that an action for accounting could be brought by the second cotenant); Wahl v. <br />Larsen, 201 P. 48, 49-50 (Colo. 1921) (recognition of a cotenant's right to enter and mine <br />without the consent of other cotenants); see also, Slade v. Rudman Resources, Inc., 230 S.E.2d <br />284, 286 (Ga. 1976) ("[T]he weight of authority is in favor of the co-tenant's right to extract <br />minerals, subject to an accounting"); White v. Smyth, 214 S.W.2d 953, 965-67 (Tex. App. 1947) <br />(accord). Thus, regazdless of the scope of the 1963 minerals reservation, Allen has the right to <br />enter the property and extract the sand and gravel. <br />8. All Easement Holders Within 200 Feet Of The Affected Lands Have Been <br />Notified. <br />On June 2, 2006, at the request of the Division and in response to Objectors' comments, <br />Allen performed a utility locate which revealed a buried Qwest cable 189 feet from Allen's <br />property boundary. See Utility Survey (Exhibit 68). Qwest was immediately notified and has <br />signed a damage compensation agreement with Allen, a waiver of formal notification and <br />statement of no objection to the proposed operation (Exhibit 73). Objectors have also azgued <br />[hat Allen should have notified the holder of a utility easement for an overhead power line near <br />Allen's property. As depicted in Exhibit B to Allen's application, that power line, described in <br />the affidavit of Objector Kent Rolf, is approximately 1320 feet to the northeast of the property <br />boundazy, well outside of the 200-foot radius specified in the Division's guidance cited by <br />Objectors as the basis for giving notice to nearby easement holders. Consequently, the <br />Objectors' allegations of insufficient notice to utility easement holders aze baseless. <br />13 <br />
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