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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 SOUGHT <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. Q <br /> Respectfully submitted this 36)d day of June, 1993 . <br /> By <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 />