My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
2012-05-04_GENERAL DOCUMENTS - C1981008
DRMS
>
Day Forward
>
General Documents
>
Coal
>
C1981008
>
2012-05-04_GENERAL DOCUMENTS - C1981008
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
8/24/2016 4:57:19 PM
Creation date
2/21/2014 9:53:00 AM
Metadata
Fields
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
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
14
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
jurisdiction in the absence of an exhaustion of administrative remedies." Id. See also, City of <br />Aspen, 143 P.3d at 1081 -1082 (same holding). <br />By the same reasoning the citizen suit provision at issue herein, like that at issue in City <br />of Boulder, does not create exclusive jurisdiction in the courts, and contains no language <br />suggesting it is an exception to the general Colorado requirement to exhaust remedies. <br />Therefore, plaintiffs' Second Claim must be dismissed. <br />III. Plaintiffs' Discussion of the OSM Process is Inaccurate and Irrelevant. <br />Plaintiffs devote the rest of their brief to a strange argument that their claims have been <br />"superseded" (Response Brief at 10) by further agency process which is "very far from being <br />exhausted" (id. at 11). Taking plaintiffs at their word, dismissal of this action is therefore <br />required, since plaintiffs are required to exhaust remedies before bringing suit and not after. <br />However, plaintiffs' own discussion of that administrative process reveals that the only live issue <br />remaining with the agencies is the ongoing review of PR -06 and, more generally, WFC's plan <br />for the future reclamation of the Property. That issue, however, is not one that can be raised in <br />this action and therefore plaintiffs' discussion is largely beside the point. <br />A. The Board Had Jurisdiction until Plaintiffs Failed to Invoke It. <br />Plaintiffs attempt to argue that because their complaint to OSM triggered an oversight <br />process, the Board somehow lacked original jurisdiction to hear their claims (Response Brief at 7 <br />— 8), and "admitted" as much in rejecting plaintiffs' attempts to raise them during review of PR- <br />06 before the Board (id. at 9). It would be strange indeed if the TDN process plaintiffs used <br />turns out to be incapable of triggering the Division's enforcement powers, and instead could only <br />lead to the Division "defending itself " Response Brief at 7, emphasis in original. The <br />Division's authority is not nearly as circumscribed as plaintiffs suggest. <br />
The URL can be used to link to this page
Your browser does not support the video tag.