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1979-06-06_ENFORCEMENT - M1978352 (13)
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1979-06-06_ENFORCEMENT - M1978352 (13)
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Last modified
8/11/2022 2:33:38 PM
Creation date
11/21/2007 12:37:46 PM
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Template:
DRMS Permit Index
Permit No
M1978352
IBM Index Class Name
Enforcement
Doc Date
6/6/1979
Doc Name
MEMORANDUM BRIEF IN SUPPORT OF PLAINTIFFS MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDAN
Media Type
D
Archive
No
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DRMS Re-OCR
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Signifies Re-OCR Process Performed
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was made to ascertain the hearing date and to prepare objections <br /> to the application. Unlike Palmer, notice was never formally <br /> served on the Trust (Goldman Affidavit) , nor was actual notice <br /> affected on the Trust (Goldman Affidavit) . In the Palmer case, <br /> the use of personal service, the most reliable form of service <br /> of notice, as distinguished from the sort of "constructive <br /> notice" which Defendants are attempting to construe upon <br /> Plaintiff Trust by virtue of the shared post office box, was <br /> still held to be inadequate. The court looked to the statutory <br /> provisions of the Administrative Procedure Act in Palmer, and <br /> determined that even such personal service of notice did not <br /> afford due process and the Board "should have set the matter <br /> at another time reasonably sufficient to give him all the <br /> opportunities for defense to which he was entitled. " Palmer, <br /> supra at 916. <br /> In the case at hand, nothing even approaching a delayed <br /> personal service containing the information regarding the date <br /> of the hearing, the site of the operation, and the information <br /> in the application, was ever affected on the Trust and was <br /> never proven at the Board meeting. As a consequence, clearly <br /> the statutory provisions of the Administrative Procedure Act <br /> in the instant case have been violated and due process has been <br /> disregarded. <br /> Finding of Actual Notice Unsubstantiated <br /> The fact that a letter of objection was sent to the <br /> Board from Mr. Stemwedel ; and that Chester Goldman was a general <br /> partner in a limited partnership, which held an interest in <br /> the Brush Creek Company; and that said Brush Creek Company <br /> provided statutory notice and that Mr. Goldman is one of the <br /> Trustees in the Eagle River Trust provides Defendant whatever <br /> attenuated basis they have for the finding of actual notice. <br /> -15- <br />
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