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IJ <br /> is the company from whom Mr. Nottingham acquired his property and they have <br /> continued to deal with the Brush Creek Co thruout the period of time and even <br /> until this time , there is a rinciple in the Brush Creek C o. and the appli- <br /> cation will refilct the fact that the deed that was , by which Mr. Nottingham <br /> acquired his property was signed by an individual named Chester M. Goldman <br /> as a partner in a Limited Partnership which& Brush Creek is, Brush Creek <br /> is a limited partnership, it ' s not a corporation. what we have in a way of <br /> initiating this objection is a letter from Mr. Stimwiddel and you will note <br /> at the bottom aof that letter is a carbon copy of the letter going to Chested <br /> M. Goldman as trustee of the EagleRiver Trust. so I guess what my point is <br /> is that even though technically there may have been different entities involved <br /> here Mr. Nottingham was operating under the good faith assumption that the <br /> adjoining landonwer remain the same. And even if the adjoining landowner <br /> changed, notice was adequate in fact because notice went to the Brush Creek <br /> a a partner in which was Chester M. Goldman and that same Chester Mr. Goldman <br /> was a trustee in the Eagle River Trust. So what we have , we have a multiplicity <br /> of entities but cutting thru and beneath we have the same indiividuals and <br /> another very impotant point I think is that at the same time, Mr. Stimwiddel <br /> represented not only the Eagle River Trsut because he clearly represented <br /> tehm as of February 16, 1979 with-hi when this objection was made <br /> and Mr. Stimwiddel also represented the Brush 'River Co. so we have a connection <br /> between the two entities in the sense that you have the same lawyer representing <br /> the original and landowner and the successor landowner even though they may be <br /> different entities and most importantly, you have the same principals . involved <br /> so i really have to say that I think that th e lack of notice is not a good <br /> objection here because notice in fact was implied. ? <br /> RW: Any questions that the Board has on that point. ? <br /> RT: What is the principal objection of the Trust that you just made? <br /> Why are you objecting to the permit? <br /> G: I can respond to the points that were made by Mr. McCarthy <br /> here and I can- think 1 ' 11 be responding to you as well . The principal <br /> Objection we have is the failure to notice which has not given us sufficientltime <br /> I belive Mr. Stimwiddel sent that letter on 2. 16.79 on the behalf of Eagle <br /> River Trust- he had in the past on very limited transaction represented the <br /> Eagle River Trust but he was not noticed , Eagle River Trust was never noticed <br /> of this transaction and we have not time, our firm was never noticed, the Trsut <br /> was never noticed, to analyze the application - now in a very short period of time <br /> as of February 16, when Mr. Stimwidel realized that there were contiguous <br /> landowners he felt an obligation tbough technically he was not under any obligation <br /> we were not noticed , to let you know that we and some objection, well we did <br /> not have time to develop a substantive objectison here because Feb. 16 did not <br /> give us time, - he ralized there was a problem here , we were'nt noticed and <br /> he felt there were some defects in the application which he did not have time <br /> to review , now what we the application may be fine, maybe the rights of our <br /> G,, a' ve 1 <br /> client are not affected but we want to Alive that time to entitl�/u? legally to go <br /> into this application , the requirement for notice Ls what, right after the first date o <br />