1979-03-09_ENFORCEMENT - M1978352

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• • Regulation 2 C.C.R. 407-1 Rule 2 . 22 . No such notice was effected on Plaintiff . 3 . At the Board meeting Plaintiff requested a deferral 0,00,, of final consideration on the Application and alternatively a postponement of the effective date of the approval in question. ��{� � • Neither request was granted. i✓�"i 4 . The Board made a finding that "actual notice" of the , .�,: ( application was effected on Plaintiff and approved Defendant p--&µ t�, Nottingham' s application. 6' 5 . Plaintiff did not receive the Notice of Defendant Ae"n Nottingham' s application and subsequent board consideration that he is entitled to by Article Two, Section 25 of the Constitution of the State of Colorado. 6 . Plaintiff did not receive the Notice of Defendant Nottingham' s application and subsequent board consideration that -pUrP , he is entitled to by the due process clause of the Fourteenth Amendment of the United States Constitution. 7 . Plaintiff did not receive the Notice of Defendant ��' Nottingham' s application and subsequent board consideration that he is entitled to by the Statutes of the State of Colorado, including C.R.S . 934-32-112 (10) c and C.R.S . §24-4-105 . /v 8 . Plaintiff did not receive the Notice of Defendant Nottingham' s application and subsequent board consideration that he is entitled to by Colorado State Regulation, including 2 C.C.R. 407-1 Rule 2 .2 , and 2 . 3, and Rules 2 . 36 and/or 2 . 37 . 9 . The Board action in the aforementioned matter was arbitrary or capricious , a denial of statutory right, contrary to constitutional right, power , privilege , or immunity, in excess of statutory jurisdiction, authority, purposes , or limitations , not in accord with the procedures or procedural limitation of the State Administrative Procedure Act, and as otherwise required by law, an abuse or clearly unwarranted exercise of discretion, based upon -2-