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Karp.Neu.Hanlonµ <br /> Page 4 <br /> V. Conclusion <br /> In light of the material deficiencies in both the application materials and the legal rights <br /> possessed by Scott, granting a permit to Scott would be arbitrary, capricious and an abuse of <br /> discretion by DRMS. As such, DRMS must deny the permit application. Please notify me of the <br /> time and place of the hearing on this permit as my client will be represented. <br /> Very truly yours, <br /> KARP NEU HANLON, P.C. <br /> 1 <br /> Michael J. Sawyer <br /> MJS: <br />