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' S <br /> <br />DISTRICT COURT, CITY AND COUNTY OF DENVER, STATE OF COLORADO <br />Case P:o. <br />COMPLAINT <br />WAYNE E. BOOKER AND FFANCES G. BOOKER, <br />Plaintiffs, <br />v. <br />COLORADO MINED LAND RECLAMATION BOARD AND DAVID GOSS, <br />Defendants. <br />Plaintiffs, Wa}-ne E. Booker and Frances G. Booker <br />("Bookers"), by and through their attorneys, Moses, Wittemyer, <br />Harrison and Woodruff, P.C., respectfully submit this as their <br />complaint herein pursuant to ~ 24-4-106, C.R.S., and as grounds <br />therefor, allege as follows: <br />1. This is an action fcr judicial review pursuant to <br />the provisions of § 24-4-106, C.R.S. of the approval by the <br />defendant Colorado Mired Land F.eclamation Board ("Board") of a <br />permit for a limited impact sand and gravel mining operation to <br />be conducted by defendant David Goss ("Goss") on property in <br />Section 7, T13S, R62W, 6th P.M., E1 Paso County ("Goss Property"). <br />The Goss Property is located entirely within the boundaries of <br />the Upper Black Squirrel Creek Designated Ground Water Basin <br />("Designated Basin"). <br />2. The Rcokers are the owners of the following <br />properties, both of which are located entirely within the bound- <br />aries of the Designated Basin: <br />(a) Booker Sod Farm: All cf Section 17 except <br />that portion conveyed to E1 Paso County for <br />highway as described in right-of-way deeds <br />recorded at Book 978, Page 354 and in Book <br />978, Page 391 of the records of the E1 Paso <br />Count}~ Clerk and F.ecorder; the SEy of Section <br />18; and the N=, NASA';, and N'~td!zSE; of Section <br />20; all in T14S, 86247 of the 6th P.M., E1 <br />Paso County, Colorado, comprising 1240 acres, <br />more er less. <br />