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2012-05-04_GENERAL DOCUMENTS - C1981008
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2012-05-04_GENERAL DOCUMENTS - C1981008
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Last modified
8/24/2016 4:57:19 PM
Creation date
2/21/2014 9:53:00 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
General Documents
Doc Date
5/4/2012
Doc Name
Defendants Reply Brief in Support of Motion to Dismiss for Lack of Subject Matter Jurs 2010 CV 367
From
Christopher Kamper, Craig R. Carver, Carver, Schwarz, McNab & Baily, LLC
To
District Court Montrose County Colorado
Permit Index Doc Type
General Correspondence
Email Name
DAB
Media Type
D
Archive
No
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Turning to PR -06, the OSM review of that approval is irrelevant to the instant Motion, <br />because matters pertaining to PR -06 have no place in this case. Plaintiffs already have a parallel <br />action pending, 10 -CV -548, that challenges the Board's approval of PR -06 (currently stayed at <br />plaintiffs' request). Moreover, because PR -06 was approved by the Board, it is only subject to <br />deferential review under the "substantial evidence" test of CRS § 34 -33- 128(2), and not subject <br />to de novo review as plaintiffs seek in the instant action. See, Citizens Opposing Pollution v. <br />Exxonmobil Coal U.S.A., _ N.W.3d _, 2012 Ill. LEXIS 304, slip op. at 5 (Ill. 2012) (parallel <br />Illinois statute "requires that the administrative review process is the exclusive route for ... <br />review of the terms of a mining permit" and not the citizen suit provision); Pueblo of Picuris v. <br />New Mexico Energy, Minerals and Natural Resources Dep't, 33 P.3d 916, 920 (N.M. App. <br />2001) ( "[I]t would be inconsistent and illogical for the legislature to fashion such a specific <br />course of action for these limited challenges, only to allow citizen suits to by -pass legislative <br />direction at a whim. ") Plaintiffs' discussion of PR -06 is therefore irrelevant in this action and <br />has no bearing on the instant Motion. <br />Response to Request for Evidentiary Hearing <br />Plaintiffs have failed to carry their burden to identify facts that give rise to subject matter <br />jurisdiction in this case. Rather, the Response Brief only advances purely legal, and erroneous, <br />arguments. Because no factual issues have been identified, an evidentiary hearing may not be <br />warranted. However, in light of the substantial legal questions at issue, oral argument may be <br />appropriate if the Court finds any issues unaddressed by the parties' briefings. <br />13 <br />
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