Free Motion for Order - District Court of Colorado - Colorado

Case 1:00-cv-02325-MSK-MEH

Document 380

Filed 08/22/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case No. 00-CV-2325-MSK-MEH SIERRA CLUB and MINERAL POLICY CENTER, Plaintiffs, vs. CRIPPLE CREEK AND VICTOR GOLD MINING COMPANY, ANGLOGOLD ASHANTI (COLORADO) CORP. ANGLOGOLD ASHANTI NORTH AMERICA INC. and GOLDEN CYCLE GOLD CORPORATION Defendants. and Civil Action No. 01-CV-2307-MSK-MEH SIERRA CLUB and MINERAL POLICY CENTER, Plaintiffs, vs. CRIPPLE CREEK AND VICTOR GOLD MINING COMPANY, et al., ANGLOGOLD ASHANTI (COLORADO) CORP. ANGLOGOLD ASHANTI NORTH AMERICA INC. and GOLDEN CYCLE GOLD CORPORATION Defendants. UNOPPOSED MOTION FOR APPROVAL OF STIPULATION Plaintiffs move this Court for an order approving the Stipulation dated June 25, 2007, a copy of which is attached as Exhibit A. In support, Plaintiffs would show the Court that:

Case 1:00-cv-02325-MSK-MEH

Document 380

Filed 08/22/2007

Page 2 of 3

1.

The parties have stipulated that the amended judgment entered in this action on February 14, 2007 awarding Defendants attorneys' fees [#361], and the June 28, 2006 stipulation and attendant order regarding costs to be taxed [## 340, 341], have been fully satisfied, pursuant to a settlement agreement between the parties dismissing all appeals.

2.

The parties have stipulated that all bonds previously required by the Court in this matter may be annulled and the sureties exonerated.

3.

In compliance with D.C.COLO.LCivR 7.1A, undersigned counsel certify that all of the parties have been consulted about this motion and none of them object to the entry of the relief requested herein.

Therefore, Plaintiffs respectfully request that this court enter the Order submitted herewith. DATED this 22nd day of August 2007. Respectfully Submitted, s/ Jeffrey C. Parsons Jeffrey C. Parsons Roger Flynn Western Mining Action Project 2260 Baseline Road, Suite 101A Boulder, CO 80302 303) 473-9618 John M. Barth Attorney at Law P.O. Box 409 Hygiene, CO 80533 (303) 774-8868 2

Case 1:00-cv-02325-MSK-MEH

Document 380

Filed 08/22/2007

Page 3 of 3

Randall M. Weiner, Atty. No. 23871 1942 Broadway, Suite 408 Boulder, Colorado 80302 Tel: 303-938-3773 Fax: 303-442-6622 [email protected]

CERTIFICATE OF SERVICE I, the undersigned, hereby certify that a copy of the foregoing Unopposed Motion for Approval of Stipulation was filed electronically with the Clerk of the Court on August 22, 2007 and was then forwarded electronically to the following persons via the ECF system: Eugene J. Riordan Vranesh and Raisch P.O. Box 871 Boulder, CO 80306-871 [email protected] Don Sherwood 10861 West 28th Place Denver, CO 80215 [email protected] Robert C. Troyer Hogan and Hartson One Tabor Center 1200 17th Street, Suite 1500 Denver, CO 80202 [email protected] s/ Jeffrey C. Parsons ____________________ Jeff Parsons Craig Carver Carver, Kirchhoff, Schwartz, McNab & Bailey, P.C. Hudson's Bay Centre 1600 Stout Street, Suite 1700 Denver, CO 80215

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