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2011-09-19_ENFORCEMENT - M1977300
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2011-09-19_ENFORCEMENT - M1977300
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Entry Properties
Last modified
8/24/2016 4:43:14 PM
Creation date
10/17/2011 12:01:27 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
9/19/2011
Doc Name
Reply Brief of Plaintiff Cotter Corporation
From
Cotter Corporation
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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(citation omitted); see also Ex Parte Reese, 701 S.W.2d 840, 842 (Tex. 1986) (where judgment <br />required corporation to "begin to restore [water system] to proper condition," judgment was too <br />"vague and indefinite" to support contempt order). <br />The August 2010 Order fails to meet the level of clarity required under either Shell or <br />Golden Press. Defendants contend that the August 2010 Order and December 2010 Order <br />describe "the conduct forbidden in such a manner that persons of common intelligence can <br />readily understand their meaning and application." (Joint Answer Brief at 30.) The record, <br />however, unmistakably reflects that the Division and individual Board members held different, <br />and conflicting, views on the specific action Cotter was required to take to comply with the <br />August 2010 Order. <br />In relevant part, Corrective Action Number 2 of the August 2010 Order provided: <br />The Board requires the Operator to perform the following <br />corrective actions: <br />2) Reinitiate mine dewatering and water discharge treatment <br />sufficient to bring the mine water table to a level at least 500 <br />feet below the Steve Level, and sufficient to reestablish a <br />hydraulic gradient way from Ralston Creek. Implementation <br />must occur as soon as possible, but no later than August 31, <br />2010. <br />August 2010 Order at 9, AR:0045. Far from being "clear, specific and unequivocal," as required <br />by Golden Press, this language left enormous room for interpretation. <br />Subsequent to issuance of the August 2010 Order, the Division and individual Board <br />members provided seven different, contradictory interpretations as to the precise conduct <br />required to comply with the Order: <br />14 <br />
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