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2018-02-16_ENFORCEMENT - M1977311
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2018-02-16_ENFORCEMENT - M1977311
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Entry Properties
Last modified
2/16/2018 11:41:58 AM
Creation date
2/16/2018 11:09:17 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977311
IBM Index Class Name
Enforcement
Doc Date
2/16/2018
Doc Name Note
Objectors' Response to Cotter's Motion on Burden of Proof
Doc Name
Objectors' Response to Cotter's Motion on Burden of Proof
From
INFORM
To
MLRB
Email Name
CMM
LJW
GRM
Media Type
D
Archive
No
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5 <br /> <br />Colorado State Bd. of Pharmacy v. Priem, 272 P.3d 1136 (2012). As conceded by Cotter, Priem <br />establishes that in Colorado, the applicant for a license bears the burden of proof. Here, the <br />situation bears the same analysis – Cotter is required by the MLRA and Rules to apply for <br />permission to keep its permit. Cotter’s cases attempting to shift the burden to Objectors are <br />simply not applicable. Each of those cases dealt with a situation where, but-for the action of the <br />party seeking to revoke a permit, there would have been no hearing and no chance that the permit <br />would be terminated. Here, the opposite is true – but-for Cotter’s application attempting to <br />retain its permits via temporary cessation, those permits would terminate by operation of the <br />MLRA and Rules. Cotter is affirmatively seeking to avoid termination, is required to seek a <br />Board hearing to make its case that can meet the required demonstrations – and Cotter has the <br />burden of proof. <br /> Lastly, any finding that Cotter bears no burden in this proceeding would be nonsensical. <br />The precedent that would be established by such a finding would be to effectively require the <br />Board to grant the second term of temporary cessation to any and all requesters regardless of the <br />strength or adequacy of the requester’s demonstrations. This would be contrary to the Act and <br />Rules, which squarely place an obligation on the operator to demonstrate entitlement and on the <br />Board to weight the evidence and determine whether the operator has satisfied the statutory and <br />regulatory requirements. Granting the request without requiring Cotter to meet its burden would <br />be an abuse of discretion. <br /> Read fairly, the MLRA places the discretion of whether to grant Cotter’s request in the <br />Board, and with or without an objection, a hearing is required in which Cotter bears the burden <br />to demonstrate: 1) the MLRA’s ten year non-production limitation on the Board’s power and <br />discretion has not been exceeded; and, 2) Cotter has provided proof that the standards in the
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