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2013-01-29_REVISION - C1981008
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2013-01-29_REVISION - C1981008
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Entry Properties
Last modified
8/24/2016 5:12:31 PM
Creation date
2/20/2014 7:55:50 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
1/29/2013
Doc Name
Paintiffs Opening Brief 2010 CV 548
From
Christopher G. McAnany Dufford, Waldeck, Milburn & Krohn, LLP
To
District Court, Montrose County Colorado
Type & Sequence
PR6
Email Name
DAB
Media Type
D
Archive
No
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other words, because of the extremely high quality of the Barx soils, the Bench One <br />material is not an equivalent substitute. He then proposed an alternate reclamation <br />method involving placement of a minimum of 40 inches of Barx material over the <br />Bench One on at least 70% of the 51 acres in question. Id. The Dearstyne letter <br />generally concurred with the Boyd conclusion, and in particular noted problems with <br />the Bench One material and its high rock content. R. 8450. <br />The NRCS letters confirm the deficiencies with PR6 (as later confirmed by the <br />OSM experts) and ought to have been admitted before the Board. At worst, the Board <br />should have admitted the documents subject to the condition that the other parties be <br />given the opportunity to supplement the record and meet the evidence. The exclusion <br />of the evidence is all the more puzzling, given that the Morgans were appearing pro -se <br />and reliant upon outside government experts. Undoubtedly, DRMS, with its in -house <br />expertise, was conversant with the concern by NRCS that the Bench One was not <br />comparable to the native Barx soils. Moreover, DRMS previously granted to WFC <br />multiple extensions on filing deadlines pertaining directly to the merits of PR6. See <br />R. 5815, 5830, 5887 (granting multiple decision deadline extensions to WFC). The <br />failure to consider the evidence was error, and its exclusion prejudiced the substantial <br />27 <br />
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