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1979-04-25_ENFORCEMENT - M1978352
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1979-04-25_ENFORCEMENT - M1978352
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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
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1 <br /> r • • <br /> 278 P.2d 1015, 1017 (1955) ; see also, Heron v. City of Denver, 131 <br /> Colo. 501, 283 P. 2d 647, 650-51 (1955) . '.= .o. <br /> By failing to request an adjudicatory hearing before the <br /> Board with respect to the issuance of the Nottingham Sand and <br /> Gravel Company permit, Plaintiffs have ignored a critical adminis- <br /> trative procedure and thereby failed to exhaust their administra- <br /> tive remedies. This failure to comply with a "judicial prerequi- <br /> site" to maintenance of a civil action mandates dismissal of the <br /> Complaint. Denver-Larimie-Walden Truck Line, Inc. v. Denver-Fort <br /> Collins Trade Service, Inc. , 156 Colo. 366, 399 P.2d 242, 243-44 <br /> ( 1965) . <br /> The undisputed facts of this case demonstrate the impor- <br /> tance of the exhaustion requirement and reconfirm the rationale <br /> for the rule. The Mined Land Reclamation Act and the Regulations <br /> promulgated by the Board provide that decisions upon permit appli- <br /> cations can be made in. either of two kinds of administrative pro- <br /> ceedings - public "meetings" or public "hearings" . See, Rules and <br /> Regulations, Rule 1. 51. "Meetings" are defined to mean licensing <br /> proceedings under the State Administrative Procedure Act, Section <br /> 24-4-104, C.R.S . 1973, Rules and Regulations , Rule 1. 1 (15 ) ; while <br /> "hearings" are defined to mean formal , adversary, adjudicatory <br /> proceedings under Section 24-4-105 of the Administrative Procedure <br /> Act, Rules and Regulations, Rule 1. 1(11 ) . <br /> The Mined Land Reclamation Act allows any person to file <br /> an objection, statement of support or petition for a hearing with <br /> regard to a pending permit application within 20 days following <br /> the fourth and final newspaper notice of the pending application. <br /> Section 34-32-114, C.R.S . 1973. In accord with this provision and <br /> in response to the notice of the Nottingham Sand and Gravel appli- <br /> cation which was sent to the Plaintiffs' mailing address, Plain- <br /> tiff Eagle River 1978 Trust by its attorney, Robert Stemwedel, <br /> sent a letter to the Board dated February 16, 1978 objecting to <br /> the Nottingham application. [Heifner Affidavit, 18. ] This letter, <br /> a copy of which is attached hereto as Exhibit 1 to the Heifner <br /> -7- <br />
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