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10/03/2006 13:07 IDEX INC* -~ 19702475104 <br />October 3, 2006 <br />Tyson Powell, Esq. <br />Assistant Attomey General <br />Office of the Attorney General <br />1525 Sherman Street, 5~' Floor <br />Denver, CO 80203 <br />RE: Allen Drilling and Excavating Co., Inc File No. M-2005-080 <br />Hello Attorney Powell, <br />N0.069 D01 <br />R~~iV~d• <br />OAT ~ 3 ? p06 <br />D ~ i~r~ ° Fiek9 <br />~~nir cf~~`~~:z,~~ <br />~artl3ui `'°n. <br />This letter serves as my written complaint requesting that a proceeding for <br />the revocation of Mr. Jack Allen's previously issued permit be commenced. <br />Mr. Allen through his legal representatives have engaged in unlawful activity <br />regarding their Mining and Reclamation Application. <br />Citing 24-A-104 paragraph 5 "A proceeding for the revocation, suspension, <br />annulment, limitation, or modification of a previously issued license shall be <br />commenced by the agency upon its own motion or by the filing with the <br />agency of a written complaint, signed and sworn to by the complainant, <br />stating the name of the licensee complained against and the grounds for <br />the requested action:' <br />And Citing 24-4-104 paragraph 4 "Where the agency has objective and <br />reasonable grounds to believe and finds, upon a full investigation, that the <br />licensee has been guilty of deliberate and willful violation..." <br />And Citing 24-4-104 paragraph 13 "Any applicant who, under oath, supplies <br />false Information to an agency in an application for a license commits <br />perjury in the second degre®, as defined in section 18-8-503, C.R.S. <br />And in support of Citing 24-4-102 paragraph 3 "Agency" means any board, <br />bureau, commission, department, institution, division, section, or officer of <br />the state..." <br />And in support of Citing 24-4-102 paragraph 7 "License" includes the whole <br />or any part of any agency permit,,..." <br />The Facts: <br />April 17`", 2006 -Allen through his representative Angela Bellantoni submits to <br />the Division of Minerals and Geology, referred to as the "2"d Adequacy Review <br />and Response", that the applicant agreed to the stipulation: "All structures on <br />site will be portable andlor temporary:' Sea Attachment <br />