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PERMFILE101003
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PERMFILE101003
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Entry Properties
Last modified
8/24/2016 9:55:28 PM
Creation date
11/24/2007 7:30:11 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2005080
IBM Index Class Name
Permit File
Doc Date
6/20/2006
Doc Name
Motion to ID Rebuttal Witnesses
From
Temkin Wielga Hardt & Longenecker LLP
To
DMG
Media Type
D
Archive
No
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3. Rule 2.8.1 of the Boazd's Regulations for the Extraction of Construction <br />Materials ("Rules") provides that every party to a Board proceeding shall have the right <br />"to submit rebuttal evidence." <br />4. In accordance with Rules 2.6 and 2.8.1, Allen hereby identifies Gary B. <br />Thompson as a rebuttal witness. Mr. Thompson is a licensed professional engineer who <br />has already provided an opinion included in the administrative record regarding the <br />required water quantity and supply for the project, and would testify at the formal Board <br />hearing regarding those matters and any other groundwater and hydrology issues raised <br />by the Objectors. Mr. Thompson's resume is attached hereto as Exhibit A. <br />5. Allen will identify any further necessazy rebuttal witnesses who will <br />address Objectors' newly offered testimony and exhibits no later than fifteen days before <br />the formal Board hearing. <br />6. These rebuttal witnesses will testify only in response to matters raised by <br />Objectors at the formal Board hearing. Because Objectors presented new information <br />and arguments at the prehearing conference, granting Allen's request for leave to identify <br />additional rebuttal witnesses is necessary to serve the interests of justice and fairness. <br />Because all such rebuttal witnesses will be identified well in advance of the formal Board <br />hearing, granting this motion will not result in prejudice to any of the parties. <br />Respectfully submitted this 19a' day of June, 2006. <br />TEMKIN WIELGA HARDT & <br />LONGENECKER LLP <br />By: / / <br />Sco t W. •dt, Esq. <br />Joseph .Middleton, Esq. <br />
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