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ENFORCE34971
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ENFORCE34971
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Entry Properties
Last modified
8/24/2016 7:44:42 PM
Creation date
11/21/2007 2:25:50 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1974041
IBM Index Class Name
Enforcement
Doc Name
AMENDED COMPLAINT PETITION FOR JUDICIAL REVIEW
Media Type
D
Archive
No
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~.. <br />require the MLRB to determine that it "has reason to believe that <br />there has occurred a violation of an order, permit, notice of <br />intent, or regulation issued under the authority of 'The Colorado <br />Mined Land Reclamation Act' and the requirement that 'written <br />notice shall be given to the operator or prospector of the <br />alleged violation."' <br />B. C.R.S. §39-32-124(5), which entitles all parties to <br />respond to present evidence, and to conduct cross-examination for <br />a full disclosure of the facts; <br />C. C.R.S.• §24-4-105(2) and Rule 8.22 which require <br />notice to be served personally or by first class mail at least <br />twenty (20) days prior to the hearing [as to the specific subject <br />matter of the hearing]; <br />D. C.R.S. §24-4-105(7), which entitles every "party" <br />the right to present its case or defense, submit rebuttal evi- <br />dence, and to conduct cross-examination, etc.; <br />E. C.R.S. §29-4-105(14), which requires that all <br />decisions be "served upon each party". <br />Notwithstanding, the MLRB upon motion and resolution <br />unanimously adopted, concluded that the only person or legal <br />entity having standing was Lawrence Construction Company and that <br />the "reason to believe" requirement and notice requirements were <br />unnecessary and the matter would proceed to a formal violations <br />hearing forthwith. <br />3. Defendants, Earl Lawrence, d/b/a Lawrence Construction <br />Company, and/or Lawrence Construction Company, a Colorado corpo- <br />ration, is/was a party to such agency action. <br />4. The defendant, Cooley Gravel Company, a Colorado corpo- <br />ration, made appearances at such agency action and may be a <br />party. <br />5. Plaintiff duly Eil2d a written request with the MLRB to <br />be admitted as a party to the proceedings. <br />6. At all times pertinent hereto, the plaintiff was a <br />person as defined by statute who may be affected or aggrieved by <br />agency action. <br />7. Based upon information and belief, the t4LR6 made certain <br />findings and orders on May 22, 1985, generally as Follows: <br />A. That Earl Lawrence is conducting a mining operation <br />at the Lawrence Pit. <br />e. That the operator has Failed to salvage and protect <br />topsoil pursuant to C.R.S. X534-32-116(1)(G). <br />-2- <br />
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