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GENERAL48229
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Last modified
8/24/2016 8:24:11 PM
Creation date
11/23/2007 4:11:36 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977436
IBM Index Class Name
General Documents
Doc Name
BREIF OF THIRD PARTY DEPENDANTS IN SUPPORT OF MOTION TO STRIKE THRID PARTY COMPLAINT
Media Type
D
Archive
No
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• • <br />i ~ . <br />II. <br />THE THIRD-PARTY COMPLAINT MUST BE <br />DISMISSED BECAUSE NOT BROUGHT OR <br />FILED WITHIN THE TIME PERIOD SPECI- <br />FIED IN C.R.S. 1973, 24-4-106 (Supp. <br />1979) <br />III. <br />THE PERMIT ISSUED BY THE DEFENDANT <br />MINED LAND RECLAMATION BOARD WHICH <br />THIRD-PARTY PLAINTIFF SEEKS TO HAVE <br />REVOKED IN ITS THIRD-PARTY ACTION <br />WAS LAWFULLY AND PROPERLY ISSUED <br />IV. <br />ADAMS COUNTY IS PERFECTLY CAPABLE OF <br />ENFORCING ITS ZONING RESOLUTIONS AND <br />IS IN THE THIRD-PARTY COMPLAINT IM- <br />PROPERLY SEEKING TO USE THE STATE <br />OF COLORADO TO ENFORCE ADAMS COUNTY <br />ZONING RESOLUTIONS <br />~ ARGUMENT <br />I. <br />The Third-Party Complaint must be dismissed because it <br />fails to meet the essential and logical requirements of Colo. <br />R.C.P. 14(s). A third-party complaint is proper only where <br />the third-party plaintiff seeks relief against a third-party <br />defendant for "all or part of the plaintiff's claim against <br />him." Colo. R.C.P. 14(a) The complaint herein seeks injunc- <br />tive relief against the Adams County Commissioners to restrain <br />them from the enforcement of a cease and desist order issued <br />by the commissioners on or about June 19, 1980. The relief <br />demanded in the third-party complaint is that the third-party <br />defendants revoke a certain mining permit heretofore granted. <br />Obviously, the claim in the third-party complaint is not a claim <br />over for any part of the relief requested in plaintiff's com- <br />plaint. The logic of the rule is that where there are two <br />-2- <br />
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