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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
Metadata
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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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and even if there were, this would be no obstacle to obtaining <br /> judicial review, C.R.S. 24-4-106 (2) . On March lst, Nottingham <br /> was given it' s authority to operate and was authorized <br /> to, and has proceeded in, actual operations at the Eagle Pit. <br /> The March 1st meeting was the final step in the Board' s <br /> review process, and final approval of the proposed operation <br /> and issuance of the permit was gained in that meeting. Thus , <br /> clearly this final agency action is subject to judicial <br /> review under C.R.S. 24-4-106 (2) regardless of any interpretation <br /> that Defendant may wish to give to a non-statutory exhaustion <br /> doctrine. <br /> Exhaustion Doctrine <br /> Notwithstanding the right to review granted Plaintiff <br /> pursuant to C.R.S. 24-4-106 , Plaintiff Trust is also entitled <br /> to a review upon the proper scrutiny of the judicial doctrine <br /> of exhaustion of administrative remedies. Defendant' s essential <br /> claim is that Plaintiff ' s failure to request an adjudicatory <br /> hearing is a failure to exhaust it' s administrative remedies, <br /> and thus they are barred from judicial review. This claim is <br /> inappropriate for manifold reasons . First, Plaintiff is seeking <br /> a review of "final agency action" and it is irrelevant that there <br /> may have been an alternative process by which such final action <br /> could have been accomplished . The fact is that C.R. S . 24-4-106 <br /> entitles Plaintiff to that review when the agency action is <br /> final, which it indusputably is (See supra pages 5-6) . <br /> Second, Plaintiff has indeed exhausted it ' s adminis- <br /> trative remedies. A complete avenue of administrative review <br /> has been exhausted and has come to it ' s conclusion. Plaintiff <br /> counsel appeared at the :•larch 1 Meeting and made it' s objections <br /> known and even requested a postponement of the effective <br /> -6- <br />
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