2002-08-02_PERMIT FILE - M2002004

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LAW OFFICE OF CHARLES E. BUTLER PROFESSIONAL CORPORATION 512 N. Main St., Suite H Pueblo, Colorado 81003 T ' RECEIV,a AUG ,0 2 2002 Division of Minerals and Geology CHARLES E. BUTLER TELEPHONE: (719)544-0044 FAX: (719)544-0404 July 313t, 2002 ANTHONY J. WALDRON, Environmental Protection Specialist, Division of Minerals and Geology, Department of Natural Resources, 1313 Sherman Street, Room 215, Denver, Colorado 80203 -- -- RE: Attor-n-ey---Gbj-e-c-t-ar-`- -Statement---an d----Response 5o-AppIicant7 s __ Pre-Hearing Statement In the matter of File No. M-2002-004 GCC Rio Grand, Inc., Red Rock Plant Application for 112 Permit Charles E. Butler, undersigned Attorney-Objector, hereby submits this statement and response to Applicant's Pre-Hearing Statement to Pre-Hearing Order of June 7", 2002 and Rule 2.6. I. Witnesses: Attorney-Objector requests and reserves the right to call, cross-examine, and to present evidence in response to any of the witnesses listed in Applicant's Pre-Hearing Statement and any witnesses who may provide testimony or evidence at said hearing. II. Exhibits: Attorney-Objector requests and reserves the right to question, present evidence in response and call for foundation, relevancy, materiality and clarification of any exhibit referred to Applicant's Pre-Hearing Statement. III. Information and Professional Reference Material: Attorney- Objector requests and reserves the right to question, call for foundation, relevancy,_materiality and clarification and present evidence in response to any Information and Professional Reference referred to Applicant's Pre-Hearing Statement. IV. Time: It is very difficult to determine, but 2 minutes for each witness, exhibit or reference is estimated. Respectfully submitted this 31St day of July, 2002. Charles E. Butler, #2428 Attorney-Objector C:\My Documents\LET.CEB.wpd