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must make a substantial and detrimental change in position. The <br /> reliance must be justified at the time of the representation and <br /> at the time the representation is acted upon by the claimant. <br /> Jefferson County School Dist No R-1 v Shorrev, supra; Dove v. <br /> Delgado, supra; Orsinger Outdoor Adv. Inc v. Dept . of High- <br /> ways, 752 P.2d 55 (Colo. 1988) ; University of Colorado v. Silver- <br /> man, supra; In re Marriage of Dennin and Lohf, 811 P.2d 449 <br /> (Colo. App. 1991) ; Emery Mining Corp v Secretary of Labor, 744 <br /> F. 2d 1411 (loth Cir. 1984) ; American Securities Transfer Inc. v. <br /> Pantheon Industries , Inc. , 871 F. Supp. 400 (D. Colo. 1994) . <br /> when attempting to apply equitable estoppel against the <br /> government, additional elements come into play. The government <br /> may not be estopped on the same terms as any other litigant . <br /> Heckler v Community Health Services of Crawford County, Inc. , <br /> 467 U.S . 51 (1984) ; Jafay v Board of County Com' rs of Boulder <br /> County, supra; Bentley v. Valco, Inc. , 741 P.2d 1266 (Colo. App. <br /> 1987) ; Fueston v City of Colorado Springs, supra. This is so <br /> because the interest of the citizenry as a whole in obedience to <br /> the law is undermined by the application of the doctrine to the <br /> government . Heckler, supra . <br /> Thus, estoppel of the government is an extraordinary remedy <br /> to be applied with greatest care and circumspection. United <br /> States v. Louisiana-Pacific Corp. , supra. Courts invoke estoppel <br /> against the government with great reluctance. Emery Min. Corp. <br /> v. Secretary of Labor, supra. The doctrine may only be applied <br /> 13 <br />