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,, t ) • I • <br />i3E1~TDELOW LAW FIRM. P.c. .. ~ . ~.. t. ^ u un m <br />4ttomeys at Law II I' II' I" II ""'~~ <br /> 999 <br />l;dward M. Bendelow <br />Stephen B. Johnson p E ~+C ~"C D <br />R C V <br />41an M. Keeffe C <br />Nicole Y. Pieterse <br />OCT 3 0 2001 <br />Kenneth R. Hope <br />Priscilla S. Fulmer <br />October 30, 2001 <br />Mr. Tom Shreiner <br />State of Colorado <br />Division of Minerals and Geology <br />Dept of Natural Resources <br />1313 Sherman, Suite #215 <br />Denver, CO 80203 <br />Oiyision of Minerals and Geology <br />www.bendelow,net <br />EDWARD M. BENDELOW <br />[edbendelow@bcndelow.net <br />VIA HAND DELIVERY <br />Re: Western Mobile Northern, Inc., a subsidiary of Lafarge Corp. <br />Reclamation Permit Application form <br />Dear Mr. Shreiner: <br />I am writing on behalf of my client, Jarle Halsnes regarding the above application. Please be <br />aware of the following: <br />1. Western Mobile Northern, Inc., a subsidiary of Lafarge Corporation ("Lafarge") apparently <br />submitted a Reclamation Permit Application form dated August 15, 2001 to the division. The <br />application concerns an operation that Lafarge has named River Valley Resource which is a <br />proposed gravel pit in Routt County, Colorado south of Steamboat Springs. <br />2. My client Jarle Halsnes is a party in contract with the owners of that real property, the <br />More family, for the purchase of that property. (Exhibit 1) <br />3. There is litigation pending between my client and the More family regarding the subject <br />property. The litigation is pending in the Routt County District Court and is currently scheduled <br />for trial on December 11, 2001. I enclose a copy of the Complaint. (Exhibit 2} <br />4. The basic allegation in the Complaint is that the More family wrongfully terminated its <br />contract with Jarle Halsnes and entered into a lease agreement with Lafarge corporation, <br />whereby Lafarge is intending to mine gravel from the same facility that is under contract with <br />my client and which he intended to mine. <br />5. Although the application is dated August 15, 2001, it is not listed on the Colorado Mining <br />and Geology Mining Report website (www.mining.state.co.us) as of today. <br />1120 Lincoln Street <br />Suite 1000 <br />Denver, CO 80203 <br />(303)837-9600 <br />Fax (303) 860-0311 <br />101 E. Colorado Ave., #201A <br />P. O. Box 726 <br />Telluride, CO 81435 <br />(970) 728-4300 <br />Fax (970)728-5955 <br />1120 South Lincoln Ave., #203 <br />P, O. Box 773630 <br />Steamboat Springs, CO 80477 <br />(970)879-5543 <br />Fax (970)871-9322 <br />