Information relating to memorandum of counsel (Our ref. 876).
Request
Thank you for the emails with the Memorandum of Counsel
I have attached 2 documents which refer to Memorandum of Counsel that were not included in what I received from you
- Document 1: Joint Memorandum of Counsel in relation to the Hazards Mapping Jurisdictional Issue Dated 15 December 2015
- Document 2: Letter from Andrew Feriband to Mackenzie District Council Mayor Graham Smith
These documents specifically references Joint Memorandum of Counsel that were not included in the ones you sent me, which are the ones I expected to get in my original request
Can you please find these ones for me
- Joint Memorandum of interested Parties dated 7 May 2015 relating to Plan Change 13 - agreed position on new hazard provisions (as per paragraph 2 of the attached document 1).
- Joint Memorandum of Counsel concerning the hazards and reverse sensitivity topics dated 9 November 2015 between Council and MEL (as per paragraph 4 document 1).
- Statement of Agreed facts (as per paragraph 4 of the attached document 1).
- The report to the Environment Court by Meridian Energy and the Mackenzie District Council that was to be reported to the court by the 12 February 2016 (as per paragraph 6 of the attached document).
- There is also The Joint Memorandum of Counsel between Meridian Energy Limited and the Mackenzie District Council regarding the Hazard maps dated 22 February 2016 (as per referred to in attached ocument 2 end of page 2).
- Also please can I have the Updated Hazard Maps that were filed with the environment court on 4 September 2015 (as per paragraph 3 of the attached document 1).
Response
As discussed regarding item 2 and 5 that you may need to request these from the environment court as we did not find these in our previous search of our records at council.
The other documents, whilst we can undertake a search for these through our archived records, this may take some more time to undertake and may not locate all of these that you require.
As per conversation you suggested that we don’t look further and that you will seek the documents from the environment court directly.
Also discussed if you need some assistance as to how to go about that please let us know and we will get some understanding of the court records process from our lawyers.