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1979-07-02_ENFORCEMENT - M1978352
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1979-07-02_ENFORCEMENT - M1978352
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Last modified
8/11/2022 2:33:39 PM
Creation date
11/21/2007 3:39:52 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1978352
IBM Index Class Name
Enforcement
Doc Date
7/2/1979
Doc Name
PLAINTIFFS REPLY BRIEF IN SUPPORT OF PLAINTIFFS MOTION FOR SUMMARY JUDGMENT 79-CV-1633
Media Type
D
Archive
No
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DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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It is clear even if a traditional exhaustion <br /> doctrine is applied, that Plaintiff qualifies for judicial review. <br /> Defendants ' entire argument in this regard is based merely on <br /> Plaintiff' s failure to request a particular form of agency review <br /> proceeding. The Plaintiff Trust appeared and presented it ' s <br /> objections to the Board at the March 1st Board Meeting. Said <br /> meetings are governed by the provisions of Section 24-4-104 , <br /> C. R. S. 1973 , the Rules and Regulations of the Board 1. 1 (15) and 1 . 2 . <br /> These rather extensive regulatory and statutory provisions provide <br /> guidelines for the Board' s final review of license applications. <br /> The Board at that time hears it' s own staff ' s extensive review <br /> and opinion of the application, and objections to the application <br /> are taken and reviewed. As is demonstrated by the lengthy trans- <br /> cript of the March 1st Board Meeting which has been attached as <br /> a part of the record, these reviews go into some detail regarding <br /> the nature of the application, and it ' s potential defects. Upon <br /> review of all these elements, the Board approves or denies, or <br /> may set a public hearing date, Rules and Regulations 1. 52 (1) . <br /> In the instant case, the Board did not see fit to call for a <br /> "hearing" , evidently feeling that the "meeting" sufficed to develop <br /> the record to justify it ' s findings. There is no statutory, <br /> judicial, or administrative rule which requires the Plaintiff , <br /> as an objector, to request the more formal hearing proceeding. <br /> The Plaintiff made it' s objections at the March 1st meeting, a <br /> dialogue ensued, a recess was taken to research the matters in <br /> question, Plaintiff requested relief in the form of formal or <br /> informal deferral and reconsideration of the question (which were <br /> denied) , and the Board made explicit findings of fact relating <br /> to Plaintiff ' s objections, and entered an order approving <br /> Nottingham Sand & Gravel Company' s permit application , (see Tran- <br /> script) . Notwithstanding the extensive and substantive nature of <br /> the March 1 review proceedings, Defendant seeks to estop Plaintiff from <br /> -4- <br />
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