Laserfiche WebLink
`` ~ III IIIIIIIIIIIIIIII [~~~'~~/E® <br />999 <br />':' `~ k1AR 1~ 199Q <br />GAINED WftiC <br />'.C(' ~.~.471l1M,1 r ~ .. <br />DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO <br />Case No. 89 CV 6224, Courtroom 10 <br />ANSWER BRIEF OF THE MINED LAND RECLAMATION BOARD <br />COSTILLA COUNTY COMMITTEE FOR ENVIRONMENTAL SOUNDNES£I, <br />Plaintiff, <br />v. <br />MINED LAND RECLAMATION BOARD OF THE STATE OF COLORADO, and <br />BATTLE MOUNTAIN RESOURCES, INC., <br />Defendants. <br />Defendant Mined Land Reclamation Board ("Board"), by and <br />through the undersigned attorney, hereby submits this Answer <br />Brief in response to Costilla County Committee for Environmental <br />Soundness' Opening Brief. <br />ISSUES PRESENTED <br />1. Does Rule 2.1.2.(8)(d) require an operator to obtain <br />water rights before applying for a reclamation permit? <br />2. Is the Board required to deny an incomple~~_e applica- <br />lion? <br />3. Absent a decreed water right, is there sukostantial <br /> <br />evidence in the record to support a determination of minimal dis- <br />