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home located adjacent to the quarry property), without building permits, County inspections, or a <br />Certificate of Occupancy. These zoning violations have been the subject of District Court <br />litigation and Mr. and Mrs. Wolf have been ordered by the Court to pay in excess of $75,000.00 <br />in fines and penalties for failing to obtain the requisite building permits. The owners also <br />violated Gilpin County Zoning Regulations by constructing a road on the quarry property without <br />the required grading permit. <br />In response to Gilpin County's attempt to enforce County Zoning Regulations, Mr. and <br />Mrs. Wolf have filed an "admiralty action," in which they assert that Gilpin County has no <br />authority to regulate or control any matters pertaining to his property. Mr. and Mrs. Wolf's legal <br />theories are ostensibly based on the feudal concept of "allodial title," a form of real property <br />ownership that has not been recognized for 500 years, but which is subscribed to by anti-tax and <br />anti-government groups. <br />The County of Gilpin has demonstrated that the Applicant's and, more importantly, Mr. <br />and Mrs. Wolf s compliance with Gilpin County regulations, is a vital issue in this proceeding. <br />Applicant cannot apply for a SUR permit from the County without Mr. and Mrs. Wolf s <br />signature on the application. Mr. and Mrs. Wolf's steadfast refusal to comply with County <br />regulation is placed squarely in issue here. Gilpin County's exhibits establish a clear pattern of <br />conduct regularly engaged in by the owners, and are relevant and essential to the record. Any <br />attempt by Applicant to strike or object to the subject exhibits should be denied. <br />3. Applicant's Comaliance with Gilpin County Permits Must be a 112 Permit <br />Condition <br />As set forth in detail in Objector City of Black Hawk's Motion for Conditions, Gilpin <br />County also proposes that any approval of the 112 Permit be conditioned upon compliance with <br />