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IV. Conclusion <br />In short, the City properly raises legitimate and substantive issues that must be considered by <br />the Boazd in its review of the proposed MMRR Quarry; the Applicant has failed to meet its burden of <br />showing that its mining plan will prevent harm tooff--site structures as required by C.R.S. § 34-32.5- <br />115(4)(e) and C.M.R. 6.5(4); and the Applicant has raised concerns about certain City exhibits and <br />witnesses that cannot be decided until the heazing, at which time the City will easily dispel those <br />concerns. <br />WHEREFORE, the City respectfully requests that this Board DENY Applicant's Motion to <br />Deny Party Status and to Strike Particulaz Objections, Witnesses, and Exhibits. <br />Respectfully submitted this 8a' day of December, 2005. <br />HAVES, PHILLIPS, HOFFMANN HARVEY W. CURTIS AND <br />& CARBERRY, P.C. ASSOCIATES <br />By: <br />Corey offman <br />By. 7. // <br />Harve . Curi <br />ATTORNEYS FOR OBJECTOR CITY OF BLACK HAWK, COLORADO <br />12 <br />