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Grimshaw <br />Wells Fargo Center <br />Harring 1700 Lincoln Street, Suite 3800 <br />Denver, Colorado 80203-4538 <br />303.839.3800 303.839.3838 (FAX) <br />Paul J. Hanley <br />(303) 839-3861 <br />October 30, 2009 <br />Via Hand Delivery <br />Colorado Division of Reclamation Mining & Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />Re: Transfer of Permit No. M1985029 - Alma Placer Mine <br />Dear Sir or Madam: <br />Soo'3 <br />iii MERITAS <br />LAW FIRMS WORLDWIDE <br />pjh@grimshawharring.com <br />http://www.grimshawharring.com <br />We are submitting a Transfer of Permit and Succession of Operators Application with <br />respect to the permit for the mine known as the Alma Placer Mine. Also enclosed is a check in <br />the amount of $144.00 for the filing fee. <br />This permit is somewhat unusual in that the current permitted operator is the Ducommun <br />Business Trust, but the Financial Warranty and Performance Warranty have been posted by the <br />two tenants who are conducting the actual mining operations on the property-Willits Company, <br />Inc. and Farley's Machine Shop, Ltd. The Ducommun Business Trust has sold its fee interest in <br />the property to Alma Placer Company, LLC, a Colorado limited liability company ("APC"). The <br />sale of the property was made subject to the leases with the two above-referenced tenants, and <br />APC has assumed the lessor's obligations under both leases. The leases remain in effect at this <br />time. Accordingly, our understanding is that the Financial Warranty and Performance Warranty <br />posted by each of the two tenants would remain in effect and by the submission of the enclosed <br />Application, APC requests that it be designated as the successor operator. <br />Please contact the undersigned or Ben Miller of APC at (303) 761-4770, if you have any <br />questions or comments. Thank you for your assistance. <br />Very truly yours, <br />Enclosures <br />cc: Alma Placer Company, LLC <br />Michael Berniger, Esq. <br />GRIMSHAW & HARRING <br />A Professional Corporation <br />Paul J. H nley <br />NO Y <br />Attorneys at Law <br />www.grimshawharring.com <br />Z/z2J; ?el o