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ENFORCE36148
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ENFORCE36148
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Entry Properties
Last modified
8/24/2016 7:45:34 PM
Creation date
11/21/2007 2:56:52 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Enforcement
Doc Date
4/23/2007
Doc Name
Statement of Reasons in Support of Petition For Review of Basin Resources
From
Davis Graham & Stubbs Inc
To
DRMS
Violation No.
CV2007001
Media Type
D
Archive
No
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over to the Tatums. <br />Further, because Basin has the right to repair the Tatum residence to abate the NOV, and <br />because Basin has agreed to make those repairs, there is no reason to increase the bond. There is <br />no uncompensated enforcement obligation that requires security. <br />5. CONCLUSION <br />The Division (along with the Tatums and the Boazd) previously settled this enforcement <br />action with Basin, waived any future claims for enforcement, whether known or unknown. <br />Further, the Division is an agency possessed of limited authority prescribed by the legislature - <br />and that authority does not include acting as a collection agency for private litigants. The <br />Division is required to constrain its actions to those within the scope of its authority, and leave <br />the resolution of judicial matters to the courts. For the foregoing reasons, Basin respectfully <br />requests that the Boazd vacate the NOV and reject the Bond Increase Proposal. <br />Respectfully submitted, <br />DAVIS, GRAHAM & STUBBS LLP <br />"~ <br />S t W. Anderson <br />William Bianco <br />1550 Seventeenth Street, Suite 500 <br />Denver, Colorado 80202 <br />Telephone: (303) 892-9400 <br />Fax: (303)893-1379 <br />ATTORNEYS FOR BASIN RESOURCES, INC. <br />-8- <br />
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