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ENFORCE34652
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Entry Properties
Last modified
8/24/2016 7:44:30 PM
Creation date
11/21/2007 2:17:57 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Enforcement
Doc Name
MLRB COMBINED MOTION TO DISMISS AND RESPONSE TO PLAINTIFFS APPLICATION FOR TEMPORARY RELIEF
Violation No.
CV2000009
Media Type
D
Archive
No
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supported by this Court, it should be given'`great deference" as required by the Colorado <br />Supreme Coup. Smith, 9 P.3d at 340. <br />Because in the underlying judicial revietiv proceeding the Plaintiffs will face the burden <br />of proving [hat the Boazd's reasonable interpretation of its own organic statute was incorrect in <br />the face of the "great deference" that the Court will show the Boazd's interpretation, the <br />Plaintiffs ca.~tnot show a'`substantial likelihood that they will prevail or. the merits o: the <br />judicial review action. For that reason, they have not met the threshold requirement for <br />obtaining temporary relief, and the Application for Temporary Relief should be denied. <br />B. The Plaintiffs Mav Cause Harm to Their Own Priem and Land if Thev Are <br />Granted Temporary Relief <br />In the Application for Temporary Relief the Plaintiffs request postponement of the NOV <br />hearing scheduled for April 25, 2001. As is indicated by the Plaintiffs' original complaint letter <br />to the OSM, as well as by the inspection report generated after the Division inspected the <br />Plaintiffs' property. the longer the Plaintiffs wait for a determination of whether Basin has <br />caused damage to their property the more likely it will be that the damage worsens. Because the <br />Boazd may determine that Basin caused the damage to the Plaintiffs' property in the April 25, <br />2001, heazing, a delay of th~r hearing m~v result ~~ more damage ro the Plaintiffs' Property. It <br />makes no sense to grant the temporary relief the Plaintiffs seek when there is a possibility that <br />they will be vindicated shortly by a denial of that temporary relief. For those reasons, the Boazd <br />further urges this Court to deny the Application for Temporary Relief. <br />l~ <br />
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