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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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P.2d 852 (Colo. 1987). The Division's Notice was sufficient, and Cotter had ample opportunity <br />to argue that its actions did not violate the permit. <br />IV. The Board is Lawfully Permitted to Enforce the August Order <br />A) Cotter never sought a stay of the August Order. <br />The APA does not support Cotter's argument that it is entitled to an automatic stay by <br />virtue of filing an appeal. The APA directly addresses the question of whether an order remains <br />enforceable pending judicial review, providing that, <br />Upon a finding that irreparable injury would otherwise result, the agency, upon application <br />therefor, shall postpone the effective date of the agency action pending judicial review, or <br />the reviewing court, upon application therefor and regardless of whether such an <br />application previously has been made to or denied by any agency, and upon such terms and <br />upon such security, if any, as the court shall find necessary and order, shall issue all <br />necessary and appropriate process to postpone the effective date of the agency action or to <br />preserve the rights of the parties pending conclusion of the review proceedings. <br />C.R.S. § 24 -4- 106(5) (2010). Cotter has not sought a stay in this case. Where a party makes "no <br />effort to seek preliminary injunctive relief or a stay order in order to preserve the status quo, he is <br />not in any position to complain of the very change in circumstances that he might have prevented <br />by seeking such relief." Zoning Bd. of Adjustment of Garfield Cty v. DeVilbiss, 729 P2d 353, <br />359 (Colo. 1986). Cotter might have prevented the November Hearing in its entirety had it <br />chosen to go through the proper channels to seek a stay. <br />B) In the absence of a stay, the Board may take action to enforce the August Order <br />pending judicial review. <br />In the absence of a stay, an administrative agency may enforce an appealed order, so long <br />as it does not substantively alter or vacate the order while review proceedings are pending. <br />To the extent that Cotter uses its lawsuit as a shield against enforcement action, it should be noted that <br />Cotter violated the August Order for twenty four days prior to filing its suit for judicial review. <br />20 <br />
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