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<br />IN THE UNITED STATES DISTRICT COURT <br />FOR THE DISTRICT OF COLORADO <br />V ?[ lach-?" 1h <br />Civil Action No. 04-F-2196(OES) <br />?? Terry Hankins, <br />Plaintiff, <br />v. <br />/i? Gale Norton, Secretary of Interior, et al., and <br />1/ United States of America. <br />Defendants <br />AM - II F 3-os^2-, <br /> <br />JAN 2 ?uv5 <br /> <br />ANSWER TO TWO SEPERATE MOTIONS TO DISMISS UNDER RULE 12(b)1 <br />AND UNDER RULE 12(b) 6 FEDERAL RULES OF CIVIL PROCEDURE <br />It should have been abundantly clear to Defendant that <br />Plaintiff is challenging the constitutionality of the overall <br />regulations 43CFR3715 and 43CFR 3809, based on the widespread <br />and continuing violations of the U.S. Constitutional rights <br />of numerous mining claimants in general and specifically in my <br />case where: <br />1. BLM employees lied in official reports at Ace#7 Mine <br />(1998-2005). THese lies, enumerated in the IBLA administrative <br />record(see annotated copy of inspection report of Sept.,2001, <br />which is refrenced at IBLA 162IBLA216, where the IBLA administrative <br />judge reversed the BLM NON, based on photos and affidavits that <br />were provided by Plaintiff. This action by the BLM employees, <br />alone, represents-.a-constitutional tort by the BLM.