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1999-02-09_GENERAL DOCUMENTS - C1981017 (3)
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1999-02-09_GENERAL DOCUMENTS - C1981017 (3)
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Last modified
3/15/2021 5:06:15 PM
Creation date
5/3/2012 9:34:22 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
2/9/1999
Doc Name
Response to motion to strike
From
US District Court
To
Mid-Continent Resources, Inc. & DMG
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
Tags
DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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object to the county being a party to that claim for relief, and neither does the Division.) <br /> However, Pitkin County's authority regarding post-mining land use does not appear to <br /> extend to claims one through four. Therefore, such authority does not support the county's <br /> participation in these claims. <br /> Pitkin County attempts to assert authority from certain special use permits issued to <br /> Mid-Continent Resources in order to participate in claims one through four. It is unclear to <br /> the Division from the pleadings filed by Mid-Continent Resources and Pitkin County <br /> whether these special use permits are still applicable or effective. The Division leaves that <br /> dispute to those parties. However, to the extent that any authority in the county existing from <br /> the special use permits conflicts with the Division's reclamation authority, such county <br /> authority would be preempted. Bowen/Edwards, supra. <br /> Pitkin County's asserted general interest in seeing that reclamation is completed at the <br /> site and in seeing that certain, specific reclamation tasks be done at the site does not appear to <br /> be sufficient to support the county's ability to raise defenses to claims one through four. <br /> Claims for relief one through four of the Amended Third-Party Complaint are based <br /> on allegations concerning reclamation done or to be-done at the Coal Basin mine site. Given <br /> the express language of§ 34-33-109(6), Pitkin County has no authority to set reclamation <br /> standards and the county concedes this point in its response. The county's asserted interests <br /> in these claims appear to be those of the everyday citizen or something akin to amicus curiae. <br /> As such, the question becomes whether Pitkin County has established sufficient interest to <br /> remain a party to claims one through four. <br /> It is elemental that only a real party in interest may prosecute a claim. C.R.C.P. 17(a). <br /> The real party in interest is the party who, by virtue of the substantive law, has the right to <br /> invoke the aid of the court to vindicate the legal interest in question. Ovunwo v. American <br /> Nat. Ins. Co., 936 P.2d 606 (Colo. App. 1997). Re-arding claims one through folll', the real <br /> party in interest is the Division. <br /> Please note that Pitkin County is not asserting it can compel demolition of any buildings or structures at the mine site. Indeed, <br /> it could not do so. See section 30-I5-401(I)(q),C.R S. Pitkin County states only that such demolition may affect post-mining <br /> land use. <br /> 6 <br />
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