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Henry W. Ipsen <br />Charlotte L. Neitzel <br />HOLME ROBERTS & OWEN LLP <br />1700 Lincoln Street, Suite 4100 <br />Denver, Colorado 80203-4541 <br />Telephone: (303) 861-7000 <br />Facsimile: (303) 866-0200 <br />Attorneys for Cotter Corporation <br />COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT <br />DIVISION OF ADMINISTRATION <br />WATER QUALITY CONTROL DIVISION <br />NOTICE OF VIOLATION/CEASE AND DESIST ORDER NUMBER I0-100601-1 <br />IN THE MATTER OF: COTTER CORPORATION <br />SCHWARTZWALDER MINE <br />JEFFERSON COUNTY, COLORADO <br />ANSWER OF COTTER CORPORATION (N.S.L.) <br />Cotter Corporation (N.S.L.) ("Cotter"), through its attorneys, answers the Notice of <br />Violation/Cease and Desist Order as follows: <br />Alleged Findings of Fact and Conclusions of Law <br />1. Cotter admits that it is a New Mexico no shareholder liability company in good standing <br />and registered to conduct business in the State of Colorado. Due to the vagueness of the <br />allegation, "[a]t all times relevant to the violations cited herein," Cotter is without knowledge or <br />information sufficient to form a belief as to the truth of the allegation, and on that basis denies it. <br />2. Cotter admits that it is a corporation, but denies that it is an individual, partnership, <br />association, state or political subdivision thereof, federal agency, state agency, municipality, <br />commission, or interstate body. The remaining allegations are legal conclusions and no response <br />is required at this time. <br />3. Cotter admits that the Schwartzwalder Mine is an underground mine in Jefferson County <br />near Golden, Colorado. Due to the vagueness of the allegation that the mine "include[s] but [is] <br />not limited to, the mine and mine building and structures," Cotter is without knowledge or <br />information sufficient to form a belief as to the truth of this allegation in paragraph 3, and on that <br />#1478735 Q den