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10'. M ~R-P~ / <br />RECES"_'r:~ <br />MAY 2 ~ ~ifGo '~ <br /> <br />C ~~ <br />~? <br />Division ~f Minerals and Cealogy <br />GAP, N8N <br />BEFORE THE MINED LAND RECLAMATION BOARD, <br />COLORADO DIVISION OF MINERALS AND GEOLOGY, <br />DEPARTMENT OF NATURAL RESOURCES <br />Board Address: 1313 Sherman Street, Room 318 <br />Denver, Colorado 80203 <br />Applicant: Allen Drilling and Excavating Company, Inc. <br />Objectors: Robert White, Kent Rolf, Curt Sayer and permit Application No.: <br />Fred Wisely M-2005-080 / <br />ATTORNEYS FOR OBJECTORS: <br />Harvey W. Curtis, #8,246 <br />Sheela S. Stack, #32,768 <br />Harvey W. Curtis & Associates <br />8310 South Valley Highway, Suite 230 <br />Englewood, Colorado 80112 Phone: (303) 292-1144 <br />firmncurtis-law.com <br />MOTION FOR CONTINUANCE OF PRE-HEARING CONFERENCE <br />AND BOARD HEARING, OR IN THE ALTERNATIVE, <br />THAT THE APPLICATION BE DENIED <br />The Objectors, Robert White, Kent Rolf, Curt Sayer and Fred Wisely (collectively referred <br />to as "Objectors"), by and through their undersigned counsel, hereby submit the following Motion <br />for Continuance ofPre-Hearing Conference set for June 2, 2006, and of Boazd Hearing set for June <br />14 and 15, 2006, and in support thereof state as follows: <br />1. According to the Mined Land Reclamation Board (the "Board") Rules and <br />Regulations, the Applicant must address all applicable requirements of the Colorado Land <br />Reclamation Act for the Extraction of Construction Materials, C.R.S. § 34-32.5-101 et seq. (The <br />"Act"), and the Mineral Rules and Regulations of the Mined Land Reclamation Board for the <br />Extraction of Construction Materials (the "Rules"). The Applicant has the burden of proving that <br />the application submitted to the Division ofMinerals and Geology (the "DMG")meets the minimum <br />requirements of the Act and all applicable Rules and Regulations. Applicant has failed to do so. <br />2. As a first ground for this motion, Rule 1.3(I) states that: "... all applications, public <br />notices, inspection reports, documents, maps, exhibits, correspondence, tests, analyses, records of <br />action or findings of the Boazd or Office and other information ... shall be promptly made available <br />for inspection to any member of the public at the offices of the Office ..." <br /> <br />