My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
1979-04-25_ENFORCEMENT - M1978352
DRMS
>
Day Forward
>
Enforcement
>
Minerals
>
M1978352
>
1979-04-25_ENFORCEMENT - M1978352
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
8/11/2022 2:33:37 PM
Creation date
11/21/2007 12:29:59 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1978352
IBM Index Class Name
Enforcement
Doc Date
4/25/1979
Doc Name
MEMORANDUM BRIEF IN SUPPORT OF DEFENDANTS MOTION TO DISMISS OR IN ALTERNATIVE FOR SUMMARY JUDGMENT
Media Type
D
Archive
No
Tags
DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
14
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
On <br /> v"0 mailing was received by an attorney representing the Trust [Not- <br /> W tingham Affidavit, Ex. 2] who then filed an objection to the � } <br /> 7 <br /> permit application on behalf of the Trust and subsequently dis- <br /> U j✓lip cussed the Trust' s objection with a member of the Division [Heifner <br /> W <br /> Affidavit, Ex. 1] . Finally, while the notice sent by certified <br /> / mail was directed to the Brush Creek and Eagle River Company, it <br /> is undisputed that at least one of the individual Plaintiffs, <br /> Chester M. Goldman was both a principal in Brush Creek and a <br /> trustee of the Trust. [Compare, Nottingham Affidavit, Ex. 1 with <br /> Heifner Affidavit, Ex. 2. 1 <br /> These undisputed facts demonstrate conclusively that all <br /> statutory and regulatory notice requirements were satisfied in <br /> connection with the Nottingham Sand and Gravel permit application. <br /> In addition, the undisputed facts provide ample support for the <br /> Board' s finding that all notice requirements were met and that <br /> Plaintiffs had actual notice of the permit application. <br /> Casting the notice objection in constitutional terms <br /> does not lend any greater force to Plaintiffs' claims. The U.S. <br /> and Colorado Supreme Courts have made clear that the basic and <br /> overriding due process requirement is that of "fundamental fair- <br /> ness" . Fuentes v. Shevin, 407 U.S . 67, 92 S.Ct. 1983, 32 L. Ed.2d <br /> 556 (1972 ) ; Mountain States Tel . & Tel . Co. v. Dept. of Labor & <br /> Employment, 184 Colo. 334, 520 P. 2d 586 (1974 ) ; Chroma Corp. v. <br /> County of Adams, 36 Colo. App. 345, 543 P. 2d 83 (1975 ) . The <br /> detailed, and potentially duplicative, notice requirements of the <br /> Colorado Mined Land Reclamation Act clearly go beyond this stand- <br /> ard. Compliance with the statutory requirements consequently <br /> satisfies the fundamental fairness standard. In any event, the <br /> undisputed facts make clear, and the Board so found, that Plain- <br /> tiffs had actual notice of the Nottingham Sand and Gravel permit <br /> application. . The state and federal Constitutions require no more. <br /> Colorado State Board of Medical Examiners v. Palmer, 157 Colo. 40, <br /> 400 P. 2d 914, 915 (1965 ) . <br /> -12- <br />
The URL can be used to link to this page
Your browser does not support the video tag.