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rssue. <br />The only stipulation that was entered into at the settlement conference was the Joint <br />Stipulation of Applicant and the City of Black Hawk concerning Black Hawk's Party Status, which <br />was filed with the Division on or about December 7, 2005. No other stipulations were entered into <br />or agreed to. Black Hawk believes it is wholly inappropriate for Applicant to attempt to introduce <br />informal settlement discussions as evidence before the Boazd of Black Hawk's positions, particularly <br />when Applicant entirely misrepresents statements made by Black Hawk's counsel. <br />Black Hawk maintains all of its position and requests as set forth in its Motion for <br />Conditions, and restates that the conditions proposed by Black Hawk aze authorized by law and <br />regulations and would lessen the potential harm to Black Hawk and others from the proposed quarry. <br />WHEREFORE, the City respectfully requests that this Board GRANT the City of Black <br />Hawk's Motion for Conditions and issue an order stating that any permit approved in this matter will <br />be conditioned on the terms and conditions set forth in said Motion. <br />Respectfully submitted this 12a' day of December, 2005. <br />HAYES, PHILLIPS, HOFFMANN HARVEY W. CURTIS AND <br />& CARBERRY, P.C. ASSOCIATES <br />By: <br />Corey Y. Hoffmann <br />Hilary Mogue Graham <br />By:_~ <br />Harvey W. Curtis <br />ATTORNEYS FOR OBJECTOR CITY OF BLACK HAWK, COLORADO <br />3 <br />