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PERMFILE126129
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PERMFILE126129
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Entry Properties
Last modified
8/24/2016 10:23:25 PM
Creation date
11/25/2007 2:54:24 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2004067
IBM Index Class Name
Permit File
Doc Date
6/26/2007
Doc Name
City of Black Hawk Reply Brief
From
Court of Appeals
To
MLRB
Media Type
D
Archive
No
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satisfy the statutory and regulatory obligations and requirements. Again, a <br />reasonable person, when it considers all of the evidence in this record as to the <br />inadequacies of the Reclamation Plan and Bond, would be fairly and honestly <br />compelled to agree that both the Plan and the Bond are inadequate. <br />II. Joinder In Briefs of Other Appellants <br />Estella Leopold hereby adopts and incorporates by reference, as is permitted <br />by C.A. R. 28, the Reply Briefs of the other Appellants. <br />III. Conclusion <br />As stated above, in failing to require compliance with Section 34-32.5- <br />115(4), C.R.S. and C.M.R. 6.4.13, the MLRB erred on several grounds provided in <br />C.R.S. 24-4-106, and this Court should reverse the district court's Order and the <br />MLRB's Order accordingly. In addition, there is not substantial evidence of the <br />Applicant's compliance with C.M.R. 3.1.10, 6.4.5 and 4.2.1(1) and §§ 34-32.5-116 <br />and 117, C.R.S. Thus this Court reverse the district court's Order and reverse and <br />set aside the MLRB's Order accordingly. <br />Respectfully submitted this ~~ day of June, 2007. <br />BRADLEY D. HILL,E~SQ~~. <br />By: ^:/if~ ~/~7f7 <br />Bradley D ill <br />Attorney for Appellant Estella B. <br />Leopold <br />s <br />
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