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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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application reveals that at no point during his remarks to the <br /> Board did Mr. Goldstein request a hearing on the question of <br /> notice, or on any other matter regarding the Nottingham applica- <br /> tion. [Transcript at pp. 15-37; Heifner Affidavit, $16; Nottingham <br /> Affidavit, 110. 1 <br /> There is no dispute that the Trust had the right under <br /> Section 34-32-114, C.R.S . 1973, to request an adjudicatory hearing <br /> before the Board pursuant to Section 24-4-105, C.R.S . 1973. Under <br /> the regulatory framework created by the Act, the Rules and Regula- <br /> tions and the State Administrative Procedure Act, the submission <br /> of such a request was an essential administrative procedure; <br /> because without such a hearing, the regulatory agency - and the <br /> concerned parties - have no opportunity to develop an adequate <br /> factual record on the claims or objections giving rise to the <br /> request for judicial review. <br /> Full and adequate fact finding at the administrative <br /> level , one of the primary purposes of the exhaustion requirement, <br /> see, McGee v. U.S . , 402 U.S . 479 , 91 S.Ct. 1565, 1569 (1971 ) , is <br /> of paramount importance in view of the fact that the scope of <br /> judicial review in cases such as this is limited to the record <br /> made before the administrative agency. See, Famularo v. Board of <br /> County Comm' rs. of Adams County, 180 Colo. 333, 505 P. 2d 958, 961 <br /> (1973 ) . The administrative record in this case is comprised only <br /> of permit application documents, a limited amount of correspondence <br /> and the transcript of a tape recording of the informal discussions <br /> concerning the Nottingham permit application at the March 1, 1979 <br /> Board meeting. Such a record is the normal and expected outcome <br /> of the non-adjudicatory procedures contemplated by the licensing <br /> provisions of the State Administrative Procedures Act. See, <br /> Section 24-4-104, C.R.S. 1973. This record does not, however, <br /> form an appropriate basis for judicial review of the objections <br /> forming the grounds for this action. As an objector, it was <br /> Plaintiffs' right and obligation to request an adjudicatory hear- <br /> ing at some point in the administrative proceeding. <br /> -9- <br />
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