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2012-08-10_REVISION - C1981008
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2012-08-10_REVISION - C1981008
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Entry Properties
Last modified
8/24/2016 5:05:02 PM
Creation date
2/20/2014 7:58:08 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
8/10/2012
Doc Name
Plaintiffs Response to Motion to Strike Designation of Admin Record Filed by Defendants 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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13. Accordingly, Plaintiffs submit that the best approach here, given the objections to <br />date, is for this Court to direct the parties in qualitative terms to designate the entire contents of <br />the DRMS PR -06 file, including all of the following: <br />a. all PR -06 permit submittals; <br />b. all DRMS review documents and memoranda pertaining to or generated in <br />response to PR -06; <br />C. all DRMS decision documents and memoranda provided to the Board; <br />d. all review comments and objections pertaining to PR -06 submitted by Plaintiffs <br />and other persons; <br />the transcript of all hearings pertaining to PR -06 3; <br />g. all memoranda, briefs, and exhibits (both admitted and excluded) that were <br />offered to the Board in connection with PR -06; and <br />h. all orders and decisions pertaining to PR -06. <br />Plaintiffs concur in an order to that effect and, as previously directed by the Court on June <br />12, 2012, file a proposed order consistent with this memorandum herewith. <br />WHEREFORE, Plaintiffs request that the Court enter the accompanying order approving <br />designation or record and directing transmittal of same to the Court and parties. Further, they request <br />that the motions objecting to their designation of record be denied. <br />Respectfully submitted this 10`i' day of August, 2012. <br />DUFFORD, WALDECK, MILBURN & KROHN, L.L.P. <br />By: /s/ Christopher G. McAnanv <br />Christopher G. McAnany, #21962 <br />Attorneys for Plaintiffs <br />3 Contrary to the assertion of DRMS and the Board, Plaintiffs previously purchased and obtained a written transcript <br />of the November 17, 2010 PR -06 hearing before the Board. <br />,:61 <br />
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