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<br />AFFIDA VIT OF GREG V. ETTER <br />STATE OF TEXAS § <br />§ ss. <br />COUNTY OF HARRIS § <br />Greg V. Etter duly sworn, states as follows: <br />1. I am the General Counsel of Battle Mountain Gold Company, which owns 1l)(~% of the shares <br />ofBattle Mountain Resources Inc. ("BMRI"}. <br />2. The Colorado Mmed Land Reclamation Board (the "Board") has scheduled la formal public <br />hearing to be held on March 26, 1997 regarding a notice of possible violation issued to BMRI <br />dated December 26, 1996. <br />3. Ms. Green, chair of the Board, disclosed at the February meeting of the Board that she had <br />previously been retained by the CostiUa County Conservancy District as an attorney for the <br />purpose of assisting with the development of land use regulations for Costilla County. <br />4. BMRI commented in opposition to such land use regulations on the basis that they had the <br />potential to materially adversely affect its San Luis Project. <br />5. The Costilla County Conservancy District and its representative, Maclovio Maftine.~ have been <br />consistent and vocal opponents of BMRPs San Luis Project in numerous prmceedings before <br />the Board and in other forums. <br />6. Given the fads described above and the attorney-client relationship which exists or existed <br />between Ms. Green and the Costiha County Conservancy District and ids representative <br />Page 1 of 2 <br />