PERMFILE50457

• Permit No: M2004067
• IBM Index Class Name: Permit File
• Doc Date: 12/12/2005
• Doc Name: Response to DMG Motion to Strike & Reply to DMGs Response to Citys Motion for Conditions
• From: City of Black Hawk
• To: DMG
• Media Type: D
• Archive: No

to the Division's argument, the City asserts that it is within the Boazd's jurisdiction to ensure that all
applicable laws, including local land use laws, aze upheld during the permitting process. Section 34-
32.5-115(4)(d) requires no less.
WHEREFORE, the City respectfully requests that this Boazd DENY the Division's Motion to
Strike and refrain from ruling on the Division's Response to the City's Motion for Conditions until
such time as the City presents its evidence on those issues at the boazd hearing.
Respectfully submitted this 12`" day of December, 2005.
HAYES, PHILLIPS, HOFFMANN HARVEY W. CURTIS AND
& CARBERRY, P.C. ASSOCIATES
By: By:
orey Y. Hoffmann Harvey W. C is
_ Hilary Mogue Graham
ATTORNEYS FOR OBJECTOR CITY OF BLACK HAWK, COLORADO
testimony and likely would not be necessary should Mr. Wolf chose to attend the hearing.