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IN THE DISTRICT COURT IN AND FOR THE <br /> CITY AND COUNTY OF DENVER <br /> STATE OF COLORADO <br /> Civil Action No. <br /> THE EAGLE RIVER 1978 TRUST, ) <br /> CHESTER M. GOLDMAN, Trustee, ) <br /> and OLIVE McCOLLUM GOLDMAN, ) <br /> Trustee, ) <br /> Plaintiffs, ) <br /> VS. ) C 0 M P L A I N T <br /> THE BOARD OF MINED LAND ) <br /> RECLAMATION of the STATE OF ) <br /> COLORADO, and NOTTINGHAM SAND ) <br /> AND GRAVEL COMPANY, and ) <br /> individually WILLIAM E. ) <br /> NOTTINGHAM, Jr. , ) <br /> Defendants . ) <br /> COMES NOW the Plaintiff, by and through its attorney, <br /> Lamm & Schader, by William P. Goldstein, and hereby respectfully <br /> requests a review under the provisions of C .R.S . 524-4-106 of <br /> the Order of the Board of Mined Land Reclamation (hereinafter <br /> referred to as "Board" ) , approving Nottingham Sand and Gravel <br /> Company ' s (hereinafter referred to as "Nottingham") application <br /> number 78-352 , which Order was issued on March 1, 1979 . <br /> The grounds on which this review and relief from said <br /> Order is sought is as follows : <br /> 1. On or about March 1, 1979, the Board of Mined Land <br /> Reclamation, at a regular Board Meeting, approved Permit Application <br /> 78-352 of the Nottingham Sand and Gravel Company. <br /> k, 2 . The Plaintiff, an immediately adiacgpj�_reco rd <br /> lan=owner, as defined by the Board' s regulations 2 C .C.R. 407-1 <br /> Rule 2 . 22 (3) a, and Rule 1 (12) , is a party to whom notice by <br /> mail containing all the elements of 2 C .C .R. 407-1 Rule 2 .22 (2) , <br /> �r <br /> is req • ired pursuant to Statute, C.R.S . §34-32-112 (10) (b) (c) and <br /> i�" <br />