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requirements because the Colorado Commissioner of Insurance has suspended Frontier's <br />license to transact insurance business in the state of Colorado. The abatement deadline for <br />this NOV was May 14, 2001. To date, Powderhorn has not replaced the Frontier bond. On <br />May 15, 2001, the Division issued a cessation order for, among other reasons, Powderhom's <br />failure to abate NOV CV 2001-005. <br />Powderhom has filed a Petition for Formal Hearing, Extension of Time to Abate and <br />Response to NOV in regard to this second NOV. It is to this Petition that the Division now <br />responds. Many of the arguments set forth in Powderhom's first Petition concerning the <br />December NOV overlap with the arguments in Powderhorn's present petition. Accordingly, <br />the Division hereby incorporates its Response to the Petition concerning the December NOV <br />into this Response. <br />In addition to the facts, arguments and legal authority cited in the Division's response <br />to the Petition concerning the December NOV, the Division specifically responds as follows <br />to Powderhom's Petition in regard to the April NOV. <br />Factual Background and Introductory Note <br />On March 14, 2001, the Colorado Commissioner of Insurance made the following <br />determinations: <br />1. Frontier had failed to submit its 2000 annual report as required by statute. <br />