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~; ~ '~ • <br />STATE OF COLORADO <br />BEFORE THE MINED LAND RECLAf4ATIOIJ BOARD <br />PERMIT NUMBER 77-141 <br />ANSWER TO COMPLAINT OF LANDOWNER AGAINST ANDESITE ROCK <br />COMPANY <br />HALLYN F. HALL, <br />Landowner, <br />vs. <br />ANDESITE ROCK COMPANY, <br />Operator. <br />Andesite Rock Company answers the Complaint of the <br />Landowner Hallyn F. Hall as follows: <br />FIRST DEFENSE <br />Admits the allegations contained in paragraphs .l, 2, 3, <br />4, 6, 7, 11, the first sentence in paragraph 13, 17, 18, and <br />21 of the Complaint; alleges that it is without knowledge or <br />information sufficient to form a belief as to the truth of <br />the allegations contained in paragraphs 5, 8, 12, the last two <br />sentences in paragraph 13, and 14 of the Complaint; and denies <br />each and every other allegation contained in the Complaint. <br />SECOND DEFENSE <br />The Complaint fails to state a claim against Andesite <br />Rock Company upon which relief can be giaiital. <br />THIRD DEFENSE <br />The protest contained within the Complaint is untimely <br />inasmuch as it was not filed within 20 days after the date <br />of last publication of notice as required by Section 34-32-114, <br />C.R.S. 1973. <br />FOURTH DEFENSE <br />The filing of the Landowner's Complaint pursuant to <br />Section 29-4-104(5), C.R.S. 1973 is not timely. <br />