Appeal of RPC Vote Decision Findings.pdf - Humboldt County

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12) It was not proper and violative of public policy of the State of Nevada when the
RPC agreed with Jungo that good cause existed, to any extent, based on the failure of Jungo to
designate and spend sufficient money or assets to timely and effective proceed through the State
of Nevada regulatory process.
13) The RPC abused its discretion when it effectively made the citizens of Humboldt
County the guarantors of its CUP by prejudicing and damaging the appellants and citizens for
having exercised their fundamental rights as United States citizens and their First Amendment
rights. Indeed, at least one member of the RPC essentially stated that of course lawsuits
constitute good cause for an extension. The blanket failure of the RPC during its deliberation
and vote to be able to discriminate and/or discern a difference between meritorious lawsuits and
frivolous lawsuits in its deliberation is breathtaking!
14) The RPC engaged in egregious procedure by accepting as true all or most of the
representations of Jungo in its request for the extension, without question and/or without proper
investigation to confirm the truth or propriety of said representations, and by failing to impose
reasonable conditions to protect the health, safety and welfare of the appellants and the other
citizens who use the abutting land of the landfill site. Essentially, the RPC made said vote,
decision, and findings without meaningful and reasonably complete information.
WHEREFORE it is respectfully submitted by the undersigned that good cause exists for
the Humboldt County Commission to review and reverse the above referenced decision, vote and
finding of the RPC of February 11'h, 2010.