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1993-11-30_GENERAL DOCUMENTS - C1981017 (2)
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1993-11-30_GENERAL DOCUMENTS - C1981017 (2)
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Last modified
1/31/2021 7:31:28 AM
Creation date
4/30/2012 8:58:42 AM
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DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
11/30/1993
Doc Name
Case No. 93CAO297 Reply Brief
Permit Index Doc Type
General Correspondence
Media Type
D
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No
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DRMS Re-OCR
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Signifies Re-OCR Process Performed
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is clearly limited to the resolution of the violations charged in <br /> the DMG' s NOV. The violations of the CDPS Permit , alleged in the <br /> WQCD' s NOV, are not mentioned or in any way addressed in the doc- <br /> ument . <br /> Second, as a party to the agreement , DMG has the authority <br /> to bind the State only to the extent it is authorized by <br /> statute. **3 DMG lacks the authority to enforce the CDPS Permit . <br /> This is undisputable in light of the plain language of C.R.S. <br /> 25-8-202 ( 7 ) (b) ( I ) , C.R.S. ( 1989 ) . Clearly, if DMG lacks the <br /> authority to enforce the CDPS Permit, it cannot settle the CDPS <br /> Permit violations charged in the WQCD' s NOV. Therefore, the set- <br /> tlement agreement could not have resolved the violations alleged <br /> in WQCD' s NOV even if DMG had wanted to resolve them, which DMG <br /> clearly did not . <br /> Finally, given that DMG is not an adjudicatory body but <br /> only a party to an agreement, there was no adjudication involved. <br /> Circuit Court reversed, stating: "The parties did not expressly <br /> resolve the presently alleged violations in the consent decree, <br /> and we cannot rewrite their agreement to include additional mat- <br /> ters . " <br /> 3** This principle is supported by the U. S. Supreme Court ' s Sun- <br /> shine test of identity of government agencies as parties . As <br /> further discussed at pp. 11-13 of this Reply Brief, the Sunshine <br /> test precludes the doctrine ' s application if the government agen- <br /> cy in the first action lacked authority to represent the govern- <br /> ment ' s interest sought to be addressed in the second action. <br /> -8- <br />
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