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1979-06-22_ENFORCEMENT - M1978352
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1979-06-22_ENFORCEMENT - M1978352
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Last modified
8/11/2022 2:33:39 PM
Creation date
11/21/2007 11:36:20 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1978352
IBM Index Class Name
Enforcement
Doc Date
6/22/1979
Doc Name
REPLY BRIEF OF DEFENDANTS WILLIAM E NOTTINGHAM JR & NOTTINGHAM SAND & GRAVEL CO & MEMORANDUM BRIEF I
Media Type
D
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No
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DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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facts which entitle him to be admitted and <br /> the matters which he claims should be decided. " <br /> Section 24-4-105 (2) , C.R.S. 1973. <br /> A properly submitted request for a hearing would <br /> clearly satisfy the requirements of Section 24-4-105 (2) . <br /> Yet, Plaintiffs failed to submit any such statement. <br /> A review of the pertinent statutory and regulatory <br /> provisions thus reveals that Plaintiffs were not parties to <br /> the administrative proceeding concerning the Nottingham Sand <br /> & Gravel permit application before the MLRB. Absent party <br /> status, Plaintiffs have failed to satisfy yet another pre- <br /> requisite to judicial review under Section 24-4-106 of the <br /> Administrative Procudure Act and their Complaint should <br /> therefore be dismissed. <br /> III. The Board' s Finding That Plaintiffs Received <br /> the Required Notice of the Nottingham Appli- <br /> cation is Supported by Substantial Evidence <br /> on the Record and Confirmed by the Contents <br /> of Plaintiffs' Own Affidavits. <br /> Plaintiffs' Complaint seeks to have set aside the <br /> Board' s finding that Plaintiffs, as alleged adjacent landowners, <br /> received actual and hence adequate notice of the Nottingham <br /> application. See, Transcript of the March 1, 1979 Mined <br /> Land Reclamation Board Meeting at pp. 34-35, Barry Affidavit, <br /> Exhibit 1. To the extent that Plaintiffs seek to set aside <br /> the Board ' s express finding as arbitrary and capricious, <br /> they are obligated to demonstrate that the finding is unsup- <br /> ported by any competent evidence. Board of County Commis- <br /> sioners v. Simmons, 177 Colo. 344 , 494 P.2d 85, 87 (1972) . <br /> Apart from the arbitrary and capricious charge, the finding <br /> of the Board must be affirmed if supported by substantial <br /> evidence when the record is viewed as a whole. Lassner v. <br /> Civil Service Commission, 177 Colo. 257, 493 P.2d 1087, 1089 <br /> (1972) . <br /> The facts set forth in Defendants' earlier Memo- <br /> randum Brief at pp. 11-13, and related Affidavits, demonstrate <br /> that the Board' s finding is not only supported by competent <br /> evidence, but confirmed by substantial, indeed overwhelming, <br /> -9- <br />
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