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2011-08-11_ENFORCEMENT - M1977300
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2011-08-11_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:36:47 PM
Creation date
10/17/2011 12:01:17 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
Enforcement
Doc Date
8/11/2011
Doc Name
Joint Answer Brief
From
MLRB and DRMS
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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issue ...." R:0289, 11 -22. The Board's interpretation effectuates the purposes underlying the <br />legislative scheme. North Colorado, 914 P.2d at 907. The Boards reasonable interpretation <br />should prevail over Cotter's literal interpretation that would conflict with legislative intent and <br />lead to absurd results. Henisse 247 P.3d at 579; see also Lucero 732 P.2d at 646. <br />B) The record warrants the Board's decision to issue a cease and desist order to <br />stop Cotter's continuing non - compliance with the Act. <br />Substantial evidence in the record supports the Board's determination that Cotter's <br />violation of the August Order represented an ongoing violation of the Act that existed at the time <br />of the November Hearing. Cotter admitted that it had not complied with Corrective Actions 2 <br />and 3, related to de- watering. R:0252, 12 -17 ( "the answer is no, we have not complied with <br />that. "). Based upon that admission, Board member Barbara Green commented "... you're still <br />violating the act. I'm comfortable." R:0284, 6 -7. Cotter's direct admission is substantial <br />evidence supporting the Board's decision because it is probative evidence that would warrant a <br />reasonable belief in the existence of ongoing violations of the Act. See Monfort, 867 P.2d at <br />125. The Board need go no further, since the Act expressly authorizes it to issue cease -and- <br />desist order if it determines that a violation of the Act exists. <br />C) The Division provided Cotter with sufficient notice of the provisions alleged to <br />be violated and the facts alleged to constitute the violation. <br />Cotter was in no way prejudiced by the Notice that the Division provided. The Act <br />requires that the Division provide notice of "the provision alleged to be violated and the facts <br />alleged to constitute the violation." C.R.S. § 34- 32- 124(1) (2010). The Notice alleged that <br />Cotter's failure to comply with the August Order represented a violation of section 124 and Rule <br />3.3.2. R:0050. Section 124 and Rule 3.3.2 outline the process by which the Board and the <br />14 <br />
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