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1979-04-25_ENFORCEMENT - M1978352
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1979-04-25_ENFORCEMENT - M1978352
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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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Affidavit, contains no request for a hearing. The absence of any <br /> hearing request is significant in light of the Board' s regulation-- -' <br /> providing that: <br /> "A written filing which objects to the granting of a <br /> permit shall not be considered by the Board as a pe- <br /> tition for hearing unless such intent is expressly <br /> stated. " Rules and Regulations, Rule 2. 35. <br /> Subsequently, the Division staff member in charge of <br /> evaluating the application contacted Mr. Stemwedel to discuss the <br /> vaguely expressed objections of the Trust as set forth in Mr. <br /> Stemwedel ' s February 16 letter. Mr. Stemwedel was unable to <br /> elaborate on the objections. [Heifner Affidavit, 19. ] Further, <br /> during the course of his conversations with Mr. Heifner, Mr. <br /> Stemwedel made no request for a hearing, nor did he at any other <br /> time contact the Division or the Board to request a hearing. <br /> [Heifner Affidavit, 110. 1 <br /> During the week prior to the March 1, 1979 Board meeting <br /> at which the Nottingham application was considered, Mr. Heifner <br /> was contacted by another attorney representing the Trust, Mr. <br /> William Goldstein. Mr. Goldstein complained that in addition to <br /> the objections raised in Stemwedel ' s February 16 letter, the Trust <br /> claimed that it had not received the required notice as an adja- <br /> cent landowner. [Heifner Affidavit, 1111. ] This claim was made <br /> notwithstanding the notice sent by certified mail to the Trust' s <br /> mailing address, which notice was accepted by an attorney for the <br /> Trust and precipitated the February 16 letter of objection. Once <br /> again, however, Mr. Goldstein at no point during his contact with <br /> the Division make any request for a hearing. [Heifner Affidavit, <br /> T13. ] <br /> Finally, on March 1, 1979, the Board considered the <br /> permit application of Nottingham Sand and Gravel Company at its <br /> regularly scheduled monthly meeting. Mr. Goldstein appeared at <br /> that meeting on behalf of the Trust and argued that the Trust had <br /> not been properly notified of the application. The transcript of <br /> that portion of the Board meeting concerning the Nottingham <br /> -8- <br />
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