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<br />Respondents Bad Boys of Cripple Creek Mining Company, Inc., Harriett Snare and <br />David Graham, did not acquire the property until April 1988 and consequently have <br />no information from 1968 to 1988. In 1988, Respondents began mining in April <br />and mined through approximately June 15. David Graham was injured in a mining <br />accident in June of 1988 and all mining activity ceased until May 1989. In 1989, <br />mining began in May and continued continuously through the end of the year. For <br />the years 1990, 1991, 1992, 1993, 1994, 1995 and 1996 mining occurred <br />sporadically year round. ' <br />B. In response to an Interrogatory from the City requesting that Bad Boys itemize <br />the quantity of turquoise Bad Boys have excavated and sold from the property, Bad Boys <br />gave the following answer: <br />1988 400 pounds <br />1989 1100 pounds <br />1990 1000 pounds <br />1991 1200 pounds <br />1992 400 pounds <br />1993 200 pounds <br />1994 200 pounds <br />1995 200 pounds <br />1996 1800 pounds <br />Total: 6500 pounds <br />According to the September, 1993 report of Carlton Gerity attached as Exhibit B, <br />800 cubic feet of earth is extracted to recover 40 pounds of turquoise. At the above <br />production levels, this would equate to a minimum of 130,000 cubic feet of excavated <br />earth.e <br />C. Starting in 1991, Bad Boys obtained a Conditional Use Permit from Teller <br />County for a portion of their property in order to conduct a tourist oriented "turquoise hunt" <br />operation. Piles of earth (purportedly containing turquoise) were excavated and deposited <br />' The annual production figures are obtained directly from the Bad Boys as set forth <br />in their November 4, 1996 Responses to Petitioners First Set of Interrogatories, Request <br />for Production of Documents and Requests for Admissions to Respondents Bad Boys of <br />Cripple Creek Mining Company, Inc., Harriett Snare and David Graham, page 5. <br />Relevant portions of Bad Boys Interrogatory Responses are attached as Exhibit G. <br />° The City does not necessarily agree with Mr. Gerity's calculations of 40 lbs. of <br />turquoise per 800 cubic feet, however that calculation would be a minimum. <br />Re: File No. M-96-081 <br />Bad Boys of Cripple Creek Mining Co. <br />Formal Objection of the City of Cripple Creek Page 6 of 8 <br />