SECTION 460:2-13-3. Contents of answer  


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  •   The permittee's answer to a show cause order shall contain a statement setting forth:
    (1)   The reasons in detail why a pattern of violations, as described in I DOM/RR Section 843.13 does not exist or has not existed, including all reasons for contesting:
    (A)   The fact of any of the violations alleged by DOM as constituting a pattern of violations;
    (B)   The willfulness of such violations; or
    (C)   Whether such violations were caused by the unwarranted failure of the permittee.
    (2)   All mitigating factors the permittee believes exist in determining the terms of the revocation or the length and terms of the suspension;
    (3)   Any other alleged relevant facts; and
    (4)   Whether a hearing on the show cause order is desired.