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2011-05-03_GENERAL DOCUMENTS - C1981008
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2011-05-03_GENERAL DOCUMENTS - C1981008
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Last modified
8/24/2016 4:33:13 PM
Creation date
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DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
General Documents
Doc Date
5/3/2011
Doc Name
Plaintiffs Response to CO DRMS Motion to Dismiss itself as a Party Defendent 2010 CV 367
From
Christopher G. McAnany Dufford, Waldeck, Milburn & Krohn, LLP
To
District Court, Montrose County, Colorado
Permit Index Doc Type
General Correspondence
Email Name
DAB
Media Type
D
Archive
No
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2. In evaluating a motion to dismiss under C.R.C.P. 12(b)(5), "all averments of material fact <br />must be accepted as true and allegations must be viewed in the light most favorable to the <br />plaintiff." O'Neill v. Simpson, 958 P.2d 1121, 1123 (Colo. 1998). <br />3. This case consists of claims of breach of contract and violations of the Colorado Surface <br />Coal Mining Reclamation Act ( "CSCMRA "), C.R.S.A. §§ 34 -33 -101, et seq. and <br />implementing regulations by Defendant Western Fuels Colorado, LLC ( "WFC "). <br />4. Plaintiffs are landowners and farmers whose prime farmland soils are protected under <br />CSCMRA. Plaintiffs are seeking monetary damages for destruction of prime farmland <br />soils that has already occurred, as well as injunctive relief ensuring that more prime soils <br />are not removed or destroyed in violation of CSCMRA. <br />5. CSCMRA expressly authorizes injunctive relief to compel compliance with its provisions. <br />C.R.S.A. § 34- 33- 135(1). CSCMRA does not provide who should be named as parties in <br />such an action and there is no case law in Colorado addressing the issue. The statute does <br />allow the Colorado Mined Land Reclamation Board or the DRMS to intervene as a matter <br />of right in any such action. C.R.S.A. § 34- 33- 135(2.5). <br />6. Defendant DRMS is the Colorado agency responsible for the enforcement of CSCMRA. <br />C.R.S.A § 34 -33 -123. <br />7. DRMS moves this court to dismiss itself as a party on the basis that Plaintiffs have not <br />alleged that DRMS engaged in any wrongful conduct. However, a party's own wrongdoing <br />is not the only basis for including it as a defendant in an action. C.R.C.P. 19 provides for <br />the joinder of other parties needed for just adjudication. <br />8. C.R.C.P. 19 provides that: <br />A person who is properly subject to service of process in the action shall be joined as <br />a party in the action if ... (2) he claims an interest relating to the subject of the action <br />and is so situated that the disposition of the action in his absence may: (A) As a <br />practical matter impair or impede his ability to protect that interest or (B) leave any of <br />the persons already parties subject to a substantial risk of incurring double, multiple, <br />or otherwise inconsistent obligations by reason of his claimed interest. <br />9. Another factor the Court may consider in determining whether a party is necessary under <br />Rule 19 is "the reluctance of a court to render a decision which will not finally settle the <br />controversy before it." Board of County Commis of County of San Miguel v. Roberts, 159 <br />P.3d 800, 808 (Colo. App. 2006). As set forth below, DRMS is a necessary party because <br />its presence is necessary to settle the controversy. <br />2 <br />
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