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PERMFILE46509
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PERMFILE46509
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Last modified
8/24/2016 10:48:40 PM
Creation date
11/20/2007 12:48:49 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2005080
IBM Index Class Name
Permit File
Doc Date
6/27/2006
Doc Name
Notice of Rebuttal Witnesses
From
Temkin Wielga Hardt & Longenecker LLP
To
DMG
Media Type
D
Archive
No
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Mr. Lytle is a registered professional engineer with over 25 years experience in <br />designing, implementing and managing surface and ground water evaluations and projects. <br />William F. Hahn, PG <br />Lytle Water Solutions LLC <br />640 Plaza Drive, Suite 170 <br />Highlands Ranch, CO 80129 <br />(303) 350-4090 <br />Mr. Hahn is a professional geologist with more than 30 yeazs experience in conducting <br />and managing hydrogeologic and water resource investigations. <br />3. Copies of Mr. Lytle's and Mr. Hahn's resumes are attached hereto as Exhibits A <br />and B, and will be provided at the Boazd's heazing. <br />4. Mr. Lytle and Mr. Hahn may testify as experts in rebuttal to evidence presented <br />by Objectors concerning the adequacy of Allen's engineering evaluation, compliance with <br />permitting requirements, ground and surface water hydrology, potential hydrologic impacts of <br />the proposed mine, ground water monitoring, water rights and water supply. <br />5. In its Motion, Allen stated that it would identify any additional rebuttal witnesses <br />no later than 15 days prior to the Boazd heazing. The Boazd hearing on Allen's application is <br />currently scheduled for July 12-13, 2006. Thus, this Notice is timely. <br />6. The rebuttal witnesses identified in this Notice will testify only in response to <br />matters raised by Objectors. Because Objectors presented new information and azguments at the <br />pre-heazing conference, allowing Allen to identify additional rebuttal witnesses who may testify <br />in response to that information is necessazy to ensure Allen a fair and just hearing. Because <br />Allen's rebuttal witnesses have been identified well in advance of the formal Board hearing and <br />those witnesses will be responding only to information provided by Objectors, granting this <br />motion will not result in prejudice to any of the parties. <br />Respectfully submitted this 26`h day of June, 2006. <br />TEMKIN WIELGA HARDT & LONGENECKER LLP <br />Scott W. Hazdt, Esq. <br />Joseph G: Middleton, Esq. <br />2 <br />
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