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MAR -03 -2003 16:01 FROM -DOL NATURAL RESOURCES <br />3038663558 T -823 P- 003/008 F-720 <br />issues raised by these two cases are substantially similar to those already raised in the Golden <br />Case in which there were several hundred pages of briefing on appeal by the parties and amici. It <br />should not be necessary to repeat all those arguments and the State recognized this fact in its own <br />brief when it preserved those issues by reference. The State cites no law that prohibits references <br />to, or incorporation of, appellate briefs that address the same legal issues when done for the sake <br />of brevity and efficiency. The State's Motion seeks to obtain an advantage by striking such <br />references when made by the Applicants, yet relying upon the same in the State's Opening Brief. <br />WHEREFORE, the District respectfully requests this Court to deny the State's Motion to <br />strike portions of the District's Answer Brief <br />Dated this ?'Oday of February, 2003. <br />PORZA.K BROWNING & BUSHONG LLP <br />Glenn E. Porzak ( #2790 ---' <br />Steven J. Bushong ( #21782) <br />929 Pearl Street, Suite 300 <br />Boulder, Colorado 80302 <br />(303) 443 -6800 <br />Attorneys for the Eagle River Water and Sanitation District <br />AB0073 -3- <br />