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3. It is necessary for CWCB members to disclose any potential conflicts of <br />interest related to the CWCB hearing, particularly relationships with parties <br />participating in the hearing, to ensure Pueblo a fair and meaningful opportunity to <br />present its case to objective decision makers. At a minimum, failure to disclose <br />potential conflicts of interest would give an appearance of partiality and bias to the <br />CWCB's review of Pueblo's application. Pueblo may seek recusal of CWCB members <br />if disclosure demonstrates that a conflict of interest may impair Pueblo's ability to <br />receive a fair and impartial hearing before the CWCB. <br />WHEREFORE, Pueblo respectfully requests that the CWCB issue an order <br />requiring all CWCB members to disclose, prior to the July 22 hearing, in writing all <br />potential conflicts of interest, including past and current employment by or <br />representation of any party participating in the CWCB hearing or any other relationship <br />with such parties that may give the appearance of impropriety. <br />Dated: July 16, 2002 <br />Respectfully submitted, <br />Anne J. tastle <br />Christopher L. Thorne <br />HOLLAND & HART LLP <br />Thomas J. Florczak <br />Assistant City Attorney <br />ATTORNEYS FOR <br />PUEBLO, A MUNICIPAL CORPORATION <br />2 <br />