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<br />above-referenced MLRD permit, said properly and commonly known as <br />Cave of the Winds. Further, on information and belief, it is <br />Mansfield's understanding that the inspection conducted t~y MLRD <br />on July 6, 1989 of the subject mine allegedly found off-site <br />impacts due to rock slides which may or in fact occurred on the <br />land of Cave of the Winds. <br />5. Mansfield believes the Board should decide if there <br />was a violation by the permit holder, i.e., Castle Concrete <br />Company and if the Board so finds should issue a cease and desist <br />order, civil penalty in the maximum amount for each day of <br />violation and order the permit be modified so as to prevent the <br />occurrence of future violations of the Colorado Mined Land <br />Reclamation Act by the permitee. <br />6. At the time of the hearing, Mansfield may call in <br />support of its case any or all of the following witnesses: <br />(a) Dr. Joyce Neville, 2617 South Wadsworth <br />Circle, Denver, Colorado 80227 as an agent and representative of <br />Mansfield Development Corporation who would testify as to the <br />background of Cave of the Winds and its operations, and the <br />impact of the subject mine's operations on Cave of the Winds; <br />(b) John W. Himmelreich, Jr., professional <br />geologist with Geotechnical Consultants, Inc., 7730 North Union, <br />Colorado Springs, Colorado 80920, who will give his expert <br />opinion on the impact of the permit violations on Cave of the <br />winds. <br />(c) Further, Mansfield reserves the right .o call <br />any and all witnesses listed and/or called by any other p+irty to <br />this proceeding. <br />7. Mansfield also reserves the right to introduce in <br />support of its position any and all exhibits listed or of~'ered by <br />any other party; and/or any and all exhibits that may be <br />necessary for purposes of rebuttal or impeachment. <br />-2- <br />