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e <br />~ III IIIIIIIIIIIII III • ,~~ <br />~.. <br /> <br />DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO <br />Civil Action No. <br />~j <br />COMPLAINT ~~; ~~ <br />`r VFW <br />~ ~ ~ ... <br />COSTILLA COUNTY CC~~~~@7MENTAL SOU'~~rC,gN- <br />Plaintiff, ~ APR ;; r 1989 ~0/V/S/0/~ <br />v . MINED LANp <br />REC1.11MATION DIVIgg~~~A*A~' <br />MINED LAND RECLAMATION BOARD OF TEfE_STATE OF COLORADO; and BATTLE <br />MOUNTAIN RESOURCES, INC., <br />Defendants. <br />The Costilla County Committee for Economic Soundness <br />("CES") for its Complaint hereby alleges as follows: <br />PARTIES <br />1. Plaintiff CES is an unincorporated group of <br />citizens of Costilla County, Colorado, including Dr. Ernest <br />Pacheco, Joseph Gallegos, Donna Koch, Prax Ortega, Michael Gomez, <br />Charles Jaquez, and Maria Gomez, who live in and around the town <br />of San Luis. CES and some of its members appeared as party <br />objectors to Application No. M-88-112 filed by Battle Mountain <br />Resources, Inc. ("Battle Mountain"). <br />2. Defendant Mined Land Reclamation Board ("NLRB") of <br />Colorado is part of the Office of the Executive Director of the <br />Colorado Department of Natural Resources, established pursuant to <br />§ 34-32-105, C.R.S. <br />3. Defendant Battle Mountain is a Nevada corporation, <br />and is a wholly-owned subsidiary of Battle Mountain Gold Company, <br />a Nevada corporation, licensed to do business in Colorado and <br />with its principal place of business in Texas. <br /> <br />