Laserfiche WebLink
ermit #: N~-a,on S - Q~(~ Confidental?: <br />Class: Type-Seq.: <br />From: ~ e c ~ To: <br />Doc. Name: ^ o a <br />Doc. Date (if no date stamp): a <br />Specialist: l.C f ~-Q , ~ I} (L ;5 u, ~ <br />BEFORE THE MINED LAND RECLAMATION BOARD, <br />COLORADO DIVISION OF MINERALS AND GEOLOGY, <br />RECI <br />DEPARTMENT OF NATURAL RESOURCES =INFO <br /> SEP 0 12006 <br />Board Address: 1313 Sherman Street, Room 318 <br />Denver, Colorado 80203 Division of Reclamation, <br /> Minin <br />and S <br />f <br />t <br /> g <br />a <br />e <br />y <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-OSO <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 />firm~curtis-law.com <br />MOTION TO DISMISS APPLICATION <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 />to Dismiss Application, or in the alternative, Continue Hearing Until Resolution of Quiet Title <br />Action ,and in support thereof state as follows: <br />On May 23, 2006, a Contract to Quiet Title and Purchase Mineral Rights ("ContracP') <br />(Exhibit A hereto) was entered into between Robert Cargill and Neighbors for a Desirable Park <br />County, Inc. ("Neighbors") By this Contract, Mr. Cargill states his parents, N.C. and Lora Cargill, <br />did by virtue ofthe 1963 Warranty Deed, which deed is part of the DMG Public record and attached <br />hereto as Exhibit B, "reserve one-half the sand and gravel under the [proposed site] ...and has <br />claimed ownership of all the sand and gravel under these lands." By virtue of this Contract, <br />