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<br />That the permit No. 77-141 be annulled or revoked; <br />2. That in the event a new permit is sought by the operator, bond <br />be increased to account for the appropriate post-mining land use, to assure <br />that the operator will have sufficient water rights to accomplish appropriate <br />reclamation and to provide for complete reclamation as is determined to be <br />necessary by the Board in a new permit proceeding. <br />3. That the Board determine that Andesite is in default on its <br />performance warranty, as set out in this Complaint, that a time certain of 30 <br />days be set for Andesite to cure such defaults, and if such defaults are not <br />cured within said 30 days, that the financial warranties of Andesite be <br />forfeited. <br />4. That the Board forthwith issue a cease and desist order against <br />the violations of notice requirements, requirements of statutes and of <br />regulations as set out by the facts alleged herein, and such facts as are <br />adduced at hearing, pursuant to Section 34-24-124 CRS 1973 as amended. <br />5. That the Board order such other relief as is authorized by <br />statute and as is shown to be warranted by the evidence presented. <br />Respectfully submitted this 315Tday of ~1~9~8~3~. <br />fYY~fi/~ <br />1 ~ eg. o. T84 <br />Attorney and Counselor at Law <br />1375 Walnut Street, Suite 215 <br />P. 0. Box 2279 <br />Boulder, CO 80306 <br />Telephone: 303/440-0075 <br />-4- <br />