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2013-03-22_REVISION - C1981008
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2013-03-22_REVISION - C1981008
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Entry Properties
Last modified
8/24/2016 5:18:46 PM
Creation date
2/20/2014 7:52:57 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
3/22/2013
Doc Name
Answer Brief of Western Fuels Colorado 2010 CV548
From
Christopher Kamper, Stewart McNab Carver, Schwarz Mc Nab & Baily, LLC
To
District Court, Montrose County Colorado
Type & Sequence
PR6
Email Name
DAB
Media Type
D
Archive
No
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material as subsoil on 20 acres of the Morgan property. Opening Brief at pp. 24- <br />25. <br />Plaintiffs ignore the binding authority that prevents consideration of OSM <br />documents and offer no contrary legal basis for the Court to consider them. <br />Because none of OSM's determinations were made, let alone available to the <br />Board by the time that MLRB made its decision on PR -6, the Court must disregard <br />OSM documents, disregard plaintiffs' statements regarding them, and disregard <br />arguments based upon them. <br />B. The Board's Exclusion of the `Midnight Letters' from NRCS Was <br />Proper. <br />Plaintiffs complain that the Board should have admitted two letters written <br />by NRCS personnel, which they claim supported their views as to the future <br />productivity of the Morgan property. Plaintiffs' Brief at 25. However, these <br />letters were properly not considered by the Board because they were not provided <br />to DRMS until the night before the hearing (after business hours) and were never <br />provided to Western Fuels - Colorado. Rather, counsel for Western Fuels- Colorado <br />obtained a copy of the letters from DRMS at the lunch break of the hearing, after <br />hours of testimony had already elapsed. In these circumstances, exclusion of the <br />letters was proper. <br />100145923 2 1 15 <br />
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