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2011-05-16_ENFORCEMENT - M1977300
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2011-05-16_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:33:32 PM
Creation date
10/17/2011 12:01:26 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
Enforcement
Doc Date
5/16/2011
Doc Name
Plaintiff's Opposition to Joint Response
From
Cotter Corporation
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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Without including any discussion or analysis, the Response also attaches four state <br />district court orders reflecting cases where parties were permitted to appear as amicus curiae. <br />These orders are unhelpful in resolving whether Amici should be allowed to file a brief in this <br />action because none of them include any discussion of why the amici in those cases were <br />allowed to participate. Several of the requests to appear as an amicus were unopposed. (Resp., <br />Ex. 1 at 1, 19.) The other orders only mention that an amicus was allowed to appear without <br />addressing the propriety of permitting such an appearance. (Id. at 3, 17.) <br />The only purpose these orders serve is to show that where permission to appear as an <br />amicus is granted, the opposing party is granted additional time to respond to the amicus <br />arguments after the granting of the motion to appear. (Id. at 18, 20.) This makes sense because <br />forcing Cotter to begin preparing a response to a brief that might not be accepted would <br />potentially result in a waste of time and resources. Thus, the Board and the Division's request to <br />require Cotter to respond to the Amicus Curiae Brief by the deadline for filing its reply brief <br />should be rejected, and Cotter should be given 30 days to respond to the Amicus Curiae Brief <br />from the date of the Court's order regarding the Motion if the Court grants the Motion. <br />Dated this 16th day of May, 2011. <br />HOLME ROBERTS & OWEN LLP <br />s /Charlotte L. Neitzel <br />Charlotte L. Neitzel, Atty. Reg. 10994 <br />Robert Tuchman, Atty. Reg. 13507 <br />Stephen D. Rynerson, Atty. Reg. 34825 <br />1700 Lincoln Street, Suite 4100 <br />Denver, Colorado 80203 -4541 <br />Telephone: (303) 861 -7000 <br />Facsimile: (303) 866 -0200 <br />Attorneys for Cotter Corporation (N.S.L.) <br />4 <br />
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