Laserfiche WebLink
r III III IIIIIIIIII III <br /> GARY E. HANISCH <br /> ,4ttomey at lam <br /> 418 MAIN •• •,I, y <br /> W ALSENBURG. COLD RADO 81089 <br /> (303) 738-1290 11'JL <br /> July 9 , 1985 MINED LANO <br /> Mined Land Reclamation Division �'E%'.=.:vIATION 01VISle- <br /> 423 Centennial Building <br /> 1313 Sherman Street <br /> Denver, Colorado 80203 <br /> RE : Cessation Order C85-013 Operator <br /> Buddy J . Healey <br /> Dear Mr. Shelton : <br /> Please accept this letter as notice of request of public <br /> hearing on the above referenced alleged violation. You will <br /> also find enclosed a check in the amount of $1 , 500 made payable <br /> to Colorado Department of Natural Resources in compliance of the <br /> appropriate regulation. I must tell you that I do not agree with <br /> your interpretation of the regulation however, in order to secure <br /> my client ' s rights we are tendering the $1 ,500 under protest . <br /> The legal and factual basis for objection to the penalty and <br /> the findings is that the area distrubed by Mr. Healey is not of <br /> the character as described in Section 34-33-117. C. R. S . in that <br /> natural land surface was not distrubed. While this is the prin- <br /> cipal legal and factual basis upon which our appeal rests , we <br /> respectfully reserve the right to bring up additional points at <br /> time of the hearing should they arise . <br /> Please notify me of the date and hour of the hearing before <br /> the Mind Land Reclamation Board. If there is a choice of hearing <br /> dates I would appreciate being contacted by your office in order <br /> to work out a date that is compatible with my schedule , on the <br /> other hand if that is impossible I will make every reasonable <br /> effort to accomodate the Board' s schedule. <br /> Thank you for your cooperation in this matter. <br /> Sincerely , <br /> Gary Hanisch <br /> GEH/dwh <br />