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Notice of Apparent Positional Bias and Motion for Disqualification of Justice Hobbs, With Authorities
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Notice of Apparent Positional Bias and Motion for Disqualification of Justice Hobbs, With Authorities
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Last modified
1/26/2010 4:41:42 PM
Creation date
7/29/2009 2:50:26 PM
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Template:
Water Supply Protection
File Number
8230.2F
Description
Colorado Supreme Court Appeal
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
8/23/2004
Author
Cynthia F. Covell
Title
Notice of Apparent Positional Bias and Motion for Disqualification of Justice Hobbs, With Authorities
Water Supply Pro - Doc Type
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ar,-ument is made yet a-ain in the present appeal. Openin-Brief at 9-10. <br />As an alternative arwment in the Golden cases, the CWCB asserted that if Fort Collins <br />retained anyvalidity, it authorized onlywater rights for structures that captured and controlled water <br />at low river flows to facilitate boat and fish passage over a dam. Covell aff. ? 9, Attachxnent H, <br />Opening Brief at 3, 14-20, 24-25 and Reply at 4, 5-6, 16-17, 23-24, and 28; Attachment I, Opening <br />Brief at 6, 16-17; and Attachment 7, Opening Brief at 5, 14-16 and Reply at 7. 7ustice Hobbs' <br />former law firm, Trout, Witwer & Freeman, argued in Golden on behalf of Northern (and its <br />Municipal Subdistrict) for the same restrictive interpretation of Fort Collins. Covell aff. ¶ 10, <br />Attachment K at 3, 4-8, 12, 19. Colorado Water Congress, another former client of Justice Hobbs, <br />made a similar argument in Golden. Covell aff. ¶¶ 2 and 10, Attachment L at 8-9; 13. Thus CWCB, <br />Northern and the Colorado Water Congress all advocated strict scrutiny of recreational in-channel <br />rights as 7ustice Hobbs had done in FoYt Collins. <br />In this appeal, the CWCB again argues for the same narrow interpretation of Fo7 t Collins. <br />Opening Brief at 9. The CWCB uses this intezpretation to support its argument that the water judge <br />erred in granting the full flow rates claimed by Upper Gunnison and in failing to recognize the limits <br />imposed by the word "minimum" in the SB 216 amendxnents. Id. In short, this argument again <br />seelcs the same strict scrutiny of recreational in-channel water rights that the CWCB, Northern and <br />Colorado Water Cbngress promoted in Golden and that Justice Hobbs had promoted in Fort Collins. <br />7ustice Hobbs recused himself in the Golden cases. Covell aff. 112, Attachments N and O. <br />He did not provide a reason for his recusal. Notably, however, before his recusal in Golden, appellee <br />City of Golden had filed a motion to disqualify 3ustice Hobbs. Covell aff. ¶ 11, Attachment M. The <br />10
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