1. Whether State action is implied by the Bureau of Land Management's (BLM) anomalous codification of C.R.S. § 34-32.5-112 (9) (c) into the Division of Reclamation and Mining Safety (DRMS) Construction Materials Rule 1.6.2 (1) (f) (g), and whether the unwarranted change in statutory intent effected the adverse denial of Notice to the Colorado Parks and Wildlife (CPW), the Plaintiff and other affected persons of the proposed land use application.

2. Whether, Larimer County was obligated by statute, to have in its employ, an ADA coordinator prior to February 12,2018.

3. Whether the Office of Mined Land Reclamation (the Office); had complied with C.R.S. § 34-32.5-112 (9) (c) by immediately sending ALL (3) groups of owners of record, mailed notice of the public comment period before the end of the public comment period on November 8,2017.

4. Whether the BLM, had applied the law unequally and denied equal protection of the the Fourteenth Amendment; by accepting the Colorado Parkas & Wildlife (CPW) 90day late agency comment and denying accommodation of the disabled Plaintiffs 1-day late public comment letter, and whether the disparity constituted discrimination based on disability in violation of 43 C.F.R. § (a) (b) (i) (vii).

5. Whether the Larimer County Department of Public Health and Environment's (LCDPHE) participation as a 4covered entity ' and advisory agency, during the public hearing, inferred that; Health Insurance Portability and Accountability Act (HIPAA) regulations were in force during the public hearing and whether Larimer County violated HIPAA regulation in 45 C.F.R. § 164.502 (a) - by compelling the Plaintiff to involuntarily disclose health information; as a requisite to availing public entity of free speech during the designated public forum.

6. Whether Larimer County Designees had violated 5 U.S.C. § 552 a (b) by conditioning awarding of program benefits, on the Plaintiff's disclosure of personal information and whether the Privacy Act required Larimer County Designees to have secured Plaintiff's written consent, prior to compelling the Plaintiff to disclose personal information, during the public hearing, which was being telecast live across the internet.

7. Whether denial of family members as interpreters to LEP participants during public hearings implies discrimination on the basis of race, color and national origin.

8. Whether, issues concerning BLM, the Office and the Division's faulty dissemination of Notice that had been:
a. Raised by the Plaintiff
b. Raised by 12 other affected persons, identified in the Adequacy review
c. Shown by the 90-day late Colorado Parks and Wildlife (CPW) Agency comment
Demonstrate that; the BLM, the Office, the Board and the Division; failed to abide by Due Process requirement of Notice, in the decision to deny standing and clearly established right to equal protection clause of the 14th Amendment - to the Plaintiff and all other legitimate persons entitled to; but denied benefit of recognized party standing to the proposed mining operation.

9. Whether, letter received by the Plaintiff from the Larimer County Planning Department establishes the Plaintiff as an owner of record affected by the proposed mining operation, identified in C.R.S.

Whether State action is implied by the Bureau of Land Management's (BLM) anomalous codification