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the location and final date for filing objections with the Board. <br /> (See 534-32-113 (10) (b) , C. R. S. 1973. This notice is to be <br /> mailed to the adjacent landowner not more than ten (10) days <br /> after the initial filing of the application with the Board. <br /> §34-32-113 (10) (b) , C. R. S. 1973 . <br /> It has been conceded by the Board and it is undisputed <br /> that Plaintiff is the owner of record of immediately adjacent <br /> lands (pages 27-28 , 33 transcript) , and it is further undisputed <br /> that notice by mail was never sent to the Eagle Trust nor proven <br /> (pages 2, 12 of Defendants.' Memo, and Olive Goldman Affidavit, <br /> paragraphs 4 and 5, and Chester Goldman Affidavit, paragraphs <br /> 17 and 18) . That these material facts are undisputed suffices <br /> as a basis for granting Plaintiffs summary judgment due to <br /> Defendants ' failure to comply with §34-32-113 (10) (c) , C.R. S. 1973 . <br /> Defendants contend that Plaintiffs received some form <br /> of actual notice which satisfied all requirements of constitutional <br /> and statutory law. This alleged "actual notice" was non-existent <br /> and nonetheless inadequate (as has been demonstrated in Plaintiffs ' <br /> initial Brief in detail - )and further the Board is required to <br /> strictly comply with the statutory requirements in any of it' s <br /> proceedings or it' s actions will be held void. Colorado State <br /> Board of Medical Examiners v. Hohu, 129 Colo. 145, 268 P . 2d 401 , <br /> 404 (1954) . Agency orders issued without proper notice to <br /> interested parties are to be considered invalid and set aside. <br /> Henderson vs. Industrial Commission, 35 Colo. App. 124 , 529 P. 2d <br /> 651, 652 (1975) ; Alcott Pharmacy, Inc. vs . State Board of <br /> Pharmacies, 35 Colo. App. , , 531 P. 2d 987 , 989 (1975) . <br /> Defendant has in it' s Reply Brief, distorted the <br /> statements and meanings of the Affidavits attached to Plaintiffs ' <br /> Memorandum Brief. Defendant attempts to create an attorney/client <br /> relationship between Robert J. Stemwedel and the Eagle River Trust; <br /> after having created that relationship Defendant attempts to <br /> -8- <br />