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Warren R. Keammerer, Ph.D. <br /> Keammerer Ecological Consultants, Inc. <br /> 5858 Woodboume Hollow Road <br /> Boulder, Colorado 80301 <br /> Summary of Mr. Keammerer's anticipated testimony: Dr. Keammerer will testify <br /> as to the plant ecology associated with the proposed plan amendment. <br /> In addition to the witnesses Western Mobile anticipates calling in its case in chief, Western <br /> Mobile may rely upon the testimony of the witnesses called by any opposing party to the formal <br /> hearing, and may examine those witnesses during direct examination. Western Mobile reserves the <br /> right to call or cross-examine any of the witnesses identified by any opposing party and to call any <br /> necessary rebuttal witnesses. <br /> IV. LIST OF EXHIBITS <br /> Western Mobile reserves the right to introduce as evidence at the formal hearing any and all <br /> of the documents included in the administrative record and the current reclamation plan amendment <br /> application that is part of that record. The Division has compiled the administrative record in this <br /> matter, which is available for public review at the Division's offices. Neither the reclamation <br /> amendment application, nor the exhibits referenced in the pending application, will be resubmitted <br /> to the Division or to opposing parties. See Section 4.c. of Proposed Pre-Hearing Order. <br /> Although Western Mobile anticipates that it may introduce as evidence any or all of the <br /> documents contained in the administrative record, Western Mobile identifies below some of the <br /> documents contained in that record that are most likely to be introduced by Western Mobile as <br /> evidence at the hearing. This listing is not intended to be exhaustive since this pre-hearing statement <br /> is being tiled prior the issuance of the final pre-hearing order. Since the issues to be considered at <br /> the June 25 formal hearing have not been finalized, Western Mobile reserves the right to supplement <br /> and amend this list of exhibits subsequent to the issuance of the final pre-hearing order.. <br /> January 11, 1982, Boulder County Board of County Commissioners Special Use Review <br /> Approval granted to Flatiron Sand& Gravel Company. <br /> April 22, 1982 approval of Permit M-81-302 issued by the Colorado Mined Land <br /> Reclamation Board. <br /> January 12, 1989 Boulder County Board of County Commissioners "Deepe Farm Pit <br /> Continuation" Special Use Review approval with site plan map, "Deepe Pit Excavation Plan <br /> with Sales and Weight Facility Added 10/26/88." <br /> April 27, 1989 Flatiron request to amend Permit M-301-82 with revised reclamation plan <br /> map entitled "Deepe Pit Reclamation Plan," dated April 27, 1989. <br /> 5 <br />