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DISTRICT COURT, PITRIN COUNTY, COLORADO <br /> CIVIL ACTION NO. 91 CV 177 <br /> COMPLAINT FOR JUDICIAL REVIEW OF ADMINISTRATIVE HEARING <br /> MID-CONTINENT RESOURCES, INC. , a Delaware corporation, <br /> Plaintiff, <br /> V. <br /> THOMAS P. LOOBY, Director, Health & Environmental Protection, <br /> Colorado Department of Health; <br /> DIVISION OF ADMINISTRATION, COLORADO DEPARTMENT OF HEALTH; <br /> WATER QUALITY CONTROL DIVISION, COLORADO DEPARTMENT OF HEALTH; <br /> DEPARTMENT OF HEALTH, STATE OF COLORADO, an agency of the State <br /> of Colorado; <br /> Defendants. <br /> Pursuant to the provisions of 11A Colo. Rev. Stat. S 25-8- <br /> 404 ( 1989 Repl. Vol. ) and 10A Colo. Rev. Stat. SS 24-4-106 ( 1988 <br /> Repl. Vol. ) , plaintiff, Mid-Continent Resources, Inc. (sometimes <br /> hereinafter "Mid-Continent" ) , seeks review of and relief from the <br /> Findings of Fact, Conclusions of Law, Ruling and Order, dated <br /> November 10, 1990, as affirmed by Order Affirming Hearing <br /> Officer's Decision, dated April 16, 1991 but not served by mailing <br /> until May 30, 1991. <br /> Plaintiff has no plain and adequate remedy otherwise <br /> provided by law and invokes the jurisdiction of this court to <br /> reverse the clearly erroneous administrative determinations below. <br /> The hearing officer below abused his discretion, entered findings <br /> of fact that are clearly erroneous and unsupported by substantial <br /> evidence when the record is considered as a whole. <br /> Mid-Continent Resources, Inc. <br /> Complaint - 1 - <br />