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Zo~~o <br />_ ~r ..,~~ -rb .~~r~ ~ m <br />RECEIVED <br />JUN 19 20U6~ <br />~Y~ <br />ltiuision ~f Minerals and Geology <br />BEFORE THE MINED LAND RECLAMATION BOARD, <br />COLORADO DIVISION OF MINERALS AND GEOLOGY, <br />DEPARTMENT OF NATURAL RESOURCES <br />Board Address: 1313 Sherman Street, Room 318 <br />Denver, Colorado 80203 <br />Applicant: Allen Drilling and Excavating Company, Inc. <br />Objectors: Robert White, Kent Rolf, Curt Sayer and permit Application No.: <br />Fred Wisely M-2005-080 <br />ATTORNEYS FOR OBJECTORS: <br />Harvey W. Curtis, #8,246 <br />David L. Kueter, 26,136 <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 />fi~curtis-law.com <br />MOTION FOR CONDITIONS <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 />for Conditions, and in support thereof state as follows: <br />As set forth in greater detail in Objectors' Objection to Hearing Date of July 12th or 13th, <br />2006 and Motion to Continue And Set the Board Hearing in August, 2006, or in the Alternative <br />Motion that the Application Be Denied, filed contemporaneously herewith, the application and the <br />record in this case are both incomplete. As a result, the application should be denied. In the event <br />of approval by the Mined Land Reclamation Board (the "Board") of the above-referenced <br />application, Objectors hereby move that any approval be specifically conditioned upon compliance <br />with the following conditions: <br />1. Groundwater Usage on Site. <br />Proposed condition: Prior to commencement of excavation on the site, the <br />Applicant shall submit to the Division an amendment to the Application reflecting <br />proposed water usage from a well on the site. The Application states in Exhibit G: <br />"Allen Drilling and Excavating will purchase the necessary volume of water from an <br />appropriate supplier." The Rationale for Recommendation for Approval Over <br />