PERMFILE133161

• Permit No: M1977141
• IBM Index Class Name: Permit File
• Doc Date: 9/16/1983
• Doc Name: ANDESITE ROCK CO ANSWERS THE COMPLAINT OF THE LANDOWNER HALLYN F HALL
• Media Type: D
• Archive: No

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STATE OF COLORADO
BEFORE THE MINED LAND RECLAMATIOfd BOARD
PERMIT NUMBER 77-141
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ANSWER TO COfdPLAINT OF LANDOWNER AGAINST ANDESITE ROCK
COMPANY
HALLYN F. HALL,
Landowner,
vs.
ANDESITE ROCK COMPANY,
Operator.
RECEIVEp
SEP 1 G 1983
MINED LAND RECLAMATION DIVISION
Colo. Dept, of Natural Rasau~ces
Andesite Rock Company answers the Complaint of the
Landowner Hallyn F. Hall as follows:
FZRST DEFEfdSE
Admits the allegations contained in paragraphs 1, 2, 3,
4, 6, 7, 11, the first sentence in paragraph 13, 17, 18, and
21 of the Complaint; alleges that it is without knowledge or
information sufficient to form a belief as to the truth of
the allegations contained in paragraphs 5, 8, 12, the last two
sentences in paragraph 13, and 14 of the Complaint; and denies
each and every other allegation contained in the Complaint.
SECOND DEFENSE
The Complaint fails to state a claim against Andesite
Rock Company upon which relief can be granted.
THIRD DEFENSE
The protest contained within the Complaint is untimely
inasmuch as it was not filed within 20 days after the date
of last publication of notice as required by Section 34-32-114,
C.R.S. 1973.
FOURTH DEFENSE
The filing of the Landowner's Complaint pursuant to
Section 24-4-104(5), C.R.S. 1973 is not timely.