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T.C. Morphis: Or they would undertake reasonable range safety and environmental litigation that are consistent with 1 the scale and scope of the activity? 2 3 Michael Harvey: No sir. 4 5 T.C. Morphis: My question is why would he seek to do any of these things, it sounds like a regulated shooting range 6 if they don’t have one. 7 8 Anthony Taibi: Objection. 9 10 T.C. Morphis: You don’t need to answer that, thank you Mr. Harvey. Is it fair to say that all the allegations and 11 assertions that Mr. Klein made, you took at face value and did not further verify? 12 13 Michael Harvey: It was difficult for me to verify considering shooting activities had ceased during the time period that 14 the NOV was issued and the appeal was being processed. 15 16 T.C. Morphis: So you did not? 17 18 Michael Harvey: As I just indicated, sir, it was difficult for me to verify since shooting activities had ceased then there 19 was nothing to verify. 20 21 T.C. Morphis: Okay. Thank you. I have no further questions at this time but I do reserve the right for direct… 22 23 Anthony Taibi: Mr. Harvey, none of those particular matters of fact which I stated in the course of significant 24 argument and discussion with you, none of those facts that Mr. Morphis pulled out, my representations were in no 25 way dispositive to your determination ultimately, were they? In other words, you had independent grounds separate 26 and apart from whether one time he let his buddy go when he was still at home or something like that. 27 28 Michael Harvey: I think the only way I am going to answer that question is as follows; the April 29 notice of violation 29 asked either that Mr. Klein submit a Class A Special Use permit to allow for expanded operations, specifically a 30 recreation amenity at the Bingham Woods Mobile Home Park, or two, he submit a Class B Special Use permit 31 application to allow for a recreation non-profit facility to be operated from the 34 acre parcel or that sufficient 32 documentation be provided to refute the claims that I was …. The appeal and subsequent letter submitted by your 33 office on Mr. Klein’s behalf obviously was an attempt to refute the comments and assertions and determinations that I 34 made in my April 29, 2013 Notice of Violation. As these letters also challenged staff on being able to produce 35 documented evidence proving that a non-profit recreation facility or that the Bingham Woods Mobile Home Park had 36 been expanded, which I did not have any, that led staff to rescind the NOV. 37 38 Anthony Taibi: In fact, any settlement discussion that we might have had and this is very strange to me coming from 39 civil court was in fact never acted upon and there was not settlement. In fact, what happened was that you decided 40 in Mr. Bryan’s colorful phrase, it is like the cop deciding to tear up the ticket so there was no settlement entered into 41 of any kind. 42 43 Michael Harvey: No formal settlement agreement was finalized because we chose to rescind the NOV based on the 44 reasons articulated in my letter. 45 46 Anthony Taibi: I’ll make argument and close out. 47 48 T.C. Morphis: No further questions for Mr. Harvey. May I call my next witness? 49 50 20