1979-06-06_ENFORCEMENT - M1978352 ‎(12)‎

• Permit No: M1978352
• IBM Index Class Name: Enforcement
• Doc Date: 6/6/1979
• Doc Name: PLAINTIFFS MOTION FOR SUMMARY JUDGMENT 79-CV-1633
• Media Type: D
• Archive: No

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IN THE DISTRICT COURT
IN AND FOR THE
CITY AND COUNTY OF DENVER
STATE OF COLORADO
U
Civil Action No. 79-CV-1633 �ku
Courtroom No. 8 JUN 6
157g
�'c'c/C
�ORNEY GFN pal/
THE EAGLE RIVER 1978 TRUST,
CHESTER M. GOLDMAN, Trustee,, )
and OLIVE McCOLLUM GOLDMAN; )
Trustee, )
Plaintiffs, )
VS. ) PLAINTIFFS ' MOTION FOR
SUMP9ARY JUDGMENT
THE BOARD OF MINED LAND )
RECLAMATION of the STATE OF )
COLORADO, NOTTINGHAM SAND )
AND GRAVEL COMPANY, and )
individually WILLIAM E. )
NOTTINGHAM, Jr. )
Defendants. )
Plaintiffs, the EAGLE RIVER 1978 TRUST, CHESTER M.
GOLDMAN, Trustee and OLIVE McCOLLUM GOLDMAN, Trustee, by their
attorneys, LAMM & SCHADER, William P. Goldstein, pursuant to
C.R.C.P. 12 & 56 move this Court for an Order awarding Plaintiff
Summary Judgment as requested in Plaintiffs ' Complaint.
As grounds for this motion, Plaintiffs, Eagle River
1978 Trust, state the following :
I .
Plaintiff was not given the notice it is entitled to
of Nottingham Sand and Gravel Company Is permit application
A. Plaintiff is a record owner of land immediately
adjacent to the effected land (Goldman affidavit) .
B. Plaintiff is therefore entitled to notice by mail which
includes a copy of the notice published in a newspaper of general
circulation to be sent to Plaintiff immediately after first publication
of said notice and said notice shall contain information regarding the
identity of the applicant, the location of the proposed mining operation,
the proposed dates of commencement and completion of the operation, the