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FROM :AGO NETT. RES. SECTION TO 303 660 7233 1ss3.0s-20 10:35 #SS3 F.06/10 <br /> 31. 4t all , ti-mes relevant herein, minerals was an agent of <br /> Resources for purposes of S 34-33-123(12) , C.R.S. <br /> 32. The defendants, all agents of Resources, have vio- <br /> lated, or failed or refused to comply with, an order or deci-sion <br /> issued by the Board or Division under CSCbmA. <br /> 33. Pursuant to 5 34-32-123(12) , C.R.S. the district ,may issue an order requiring an agent to perform reclamation and court <br /> comply\ with the orders and decisions of the Board and Division. <br /> RELIEF REQUESTED <br /> 34 . Pursuant to 634-32-123(12) , C.R.S. , the Division <br /> respectfully requests this Court to enter an injunction ordering: <br /> a. John A. Reeves to immediately complete the seal- <br /> ing of the adit/rock tunnel; immediately reclaim Mine <br /> 1, 2, 3, 4 and 5 portal areas, including portal seal- <br /> ing, structural demolition, backfilling and grading., <br /> revegetation, •and installation of sediment controls; <br /> complete reclamation of the Coal Basin Mine pursuant <br /> to the reclamation plan, the provisions of CSCMRA, <br /> the regulations promulgated thereunder, and the Final <br /> Reclamation Schedule specified in the Board order <br /> dated Hay 22, 1991; maintain the site in compliance <br /> with all applicable statutory, regulatory and permit <br /> requirements; and abate any violation of such <br /> requirements. <br /> b. Robert Delaney to immediately complete the seal- <br /> ing of the adit/rock tunnel; immediately reclaim Mine <br /> 1, 2, 3, 4 and 5 portal areas, including portal sea,i- <br /> ing, structural demolition, backfilling and grading, <br /> revegetation, and installation of sediment controls; <br /> complete reclamation of the Coal Basin Mine pursuant <br /> to the reclamation plan, the provisions of CSCMP,A, <br /> the regulations promulgated thereunder, and the ']Final <br /> Reclamation Schedule specified in the Board order <br /> dated Yay 22, 1991; maintain the site in compliance <br /> with -all applicable statutory, regulatory and permit <br /> requi <br /> rements; and abate any violation of such <br /> requirements. <br /> c. Diane Delaney to immediately complete the sealing <br /> of the adit/rock tunnel; immediately reclaim Mine 1, <br /> 2, 3, 4 and 5 portal areas, including portal sealing, <br /> structural demolition, backfilling and grading, <br /> -5- <br />