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<br />P.ugust 13, 1964 for the removal of material from the Hotchkiss Coal <br />Yard. Respondent continues to assert, however, that Petitioner must <br />remove the same from the Hotchkiss Coal Yard despite Petitioner's <br />lack of any right to do so. A copy of said modification is attached <br />hereto and by reference incorporated herein. <br />10. Petitioner requests a formal hearing before this Board <br />with Denver, Colorado as the hearing site and further requests said <br />hearing be held at this Board's earliest regularly scheduled hearing <br />docket. <br />WHEREFORE, Petitioner prays that said NOV be vacated and held <br />for naught, that the Board herein expressly find that the material <br />described in said NOV is beyond the jurisdiction of Respondent, that <br />Petitioner be awarded its costs and fees herein expended as allowed <br />by law and such other relief deemed just and equitable. <br />Respectfully submitted, <br />~~ <br />~'' ~~ <br />j Thomas F~. Linn <br />Attorney at Law, No. 9823 <br />555 Seventeenth Street <br />Denver, Colorado 60202 <br />Telephone No. AC 303 293-4234 <br />CERTIFICATE OF SERyICE <br />I hereby certify that on the ~~ day of~~.r¢fiJ 1984 a <br />copy of the foregoing "Petition for Review of Notice of Violation" <br />was served, certified mail, return receipt requested upon: <br />Colorado Mined Land Reclamation Board <br />1313 Sherman Street <br />Room 923 <br />Denver, Colorado 80203 ~ <br />~-1 <br />.~- , <br />~~.~ <br />~1~1 <br />-3- <br />