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ENFORCE28260
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Last modified
8/24/2016 7:35:37 PM
Creation date
11/21/2007 11:53:26 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Enforcement
Doc Date
4/14/2000
Doc Name
OSMS NOTICE OF OPPOSITION TO APPLICANTS MOTION TO STRIKE
Violation No.
TD1993020370005TV3
Media Type
D
Archive
No
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<br />reconsideration matter is closed. Until such time as the Board <br />issues Such an order, OSM believes that is appropriate and <br />desirable for OSM to submit pleadings that address the <br />substantive issues in this matter. By so doing, OSM assists the <br />Board in its rAsolution of this matter. <br />•Second, OSM disagrees that the arguments made on pages 7-9 <br /> <br />of the Response are "new_" The three arguments made on pages 7-9 <br />of the Response were either made in rebuttal to assertions made <br />by the Appellant or were clarifications of .positions taken by OSM <br />in its Petition or earlier pleadings. In fact, as stated by OSM <br />on page 7 of the Response, one of the arguments the Appellant <br />refers to was actually raised by OSM in its Answer of April 7, <br />1997. <br />OSM believes that it has fully discussed its positions on <br />• <br />the issues in this reconsideration matter_ As a result, OSM does <br />not wish to respond further to the assertions in the Appellant's <br />most recent pleading, as such a response would be unnecessarily <br />repetitive. OSM believes that the arguments it has made to date <br />are significant, were submitted in an administratively proper <br />manner, and are worthy of the Board's Consideration. <br />Therefore, for the foregoing reasons, OSM humbly and <br />2 <br />£0 •d T£~ST 00, ZT ~dtl <br />855£998£0£~Xed <br /> <br />
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