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_GENERAL DOCUMENTS - C1981017 (181)
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_GENERAL DOCUMENTS - C1981017 (181)
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Last modified
11/2/2020 8:46:00 AM
Creation date
10/19/2012 10:19:42 AM
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DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Name
Bid Documents (IMP) Court Appeals
Permit Index Doc Type
General Correspondence
Media Type
D
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1959) ; Henn on Agency & Partnership at 94-95; 2A C.J.S . Agency <br /> § 134 (1972) ; 3 Am. Jur. 2d Agency § 59 (1986) ; Delbrueck & Co. v. <br /> Manufacturers Hanover Trust Co. , 609 F.2d 1047, 1052 (2d Cir. <br /> 1979) ; Lewis Sagal & Co. v. Smith, 35 F.2d 182, 183 (3d Cir. <br /> 1929) ; In re Universal Motor Express Inc. , 72 B.R. 208, 210 <br /> (W.D.N.C. 1987) ; In re Matter of Maplewood Poultry Co. , 2 B.R. <br /> 550, 553 (D. Me. 1980) . At that point in time, therefore, these <br /> defendants were divested of authority to effect compliance with <br /> the Board order, and they cannot be held liable for violating the <br /> same. <br /> The fact that these defendants could not have been agents is <br /> also illustrated by the "automatic stay" provision of federal <br /> bankruptcy law. 11 U.S.C..S. § 362 (a) (3) (1985) . This provision <br /> prohibits "any act to obtain possession of property of the estate <br /> or to exercise control over the property of the estate. " 11 <br /> U.S.C.S. § 362 (a) (3) (1985) (emphasis added) . These defendants <br /> could not have been agents of Resources for purposes of the <br /> reclamation statute if they had no power to cause reclamation to <br /> occur. By virtue of the automatic stay, they had no such power. <br /> Therefore, these defendants were not agents within the meaning of <br /> the statute at the time of the alleged violation, and the <br /> complaint must be dismissed for failure to state a claim for <br /> relief against them. <br /> B. THE COMPLIANCE SCHEDULE IS A NULLITY AND THE <br /> BOARD HAS FAILED TO FOLLOW PROPER PROCEDURE. <br /> The Amended Complaint also fails to state a claim because the <br /> compliance schedule it seeks to enforce is a nullity. <br /> -6- <br />
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