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P&M reserves the right to expand the facts, claims and <br />defenses of this Application as may be necessary during the <br />course of this proceeding. <br />RELIEF BOIIGHT <br />Based on the foregoing P&M requests the following relief be <br />ordered by the Colorado Mined Land Reclamation Board: <br />A. that there was no failure to establish sediment control <br />measures at the locations cited in NOV-26 and there was no <br />failure to retain sediment or other material in areas authorized <br />for disturbance. Accordingly, NOV-26 was written in error and is <br />vacated; <br />B. that P&M be granted an evidentiary hearing on its <br />Application for Formal Review with sufficient notice of hearing <br />to allow for discovery prior to such hearing; <br />C. that P&M be granted its attorney's fees and costs in <br />this matter; and <br />D, that P&M be granted such other and further relief as <br />may be just and proper. ,n <br />Respectfully submitted this 3(~ffi day of June, 1993. <br />By v., <br />J n A. Bachmann <br />torney for The Pittsburg & <br />dway Coal Mining Co. <br />6400 So. Fiddler's Green Circle <br />Englewood, Colorado 80111-4991 <br />(303) 930-4090 <br />-6- <br />