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DISTRICT COURT, WATER DIVISION 7, COLORADO <br />1060 East Second Avenue <br />Durango, Colorado 81301 <br />(970) 247 -2304 <br />CONCERNING THE APPLICATION FOR WATER RIGHTS OF <br />CITY OF DURANGO IN LA PLATA COUNTY, COLORADO <br />Court Use Only <br />Frank J. Anesi, Reg. 1365 <br />Attorney for Objector <br />P. O. Box 2185 Case No. 2006 CW 9 <br />Durango, Colorado 81302 <br />(970) 247 -9246 <br />frank@fjanesi.com <br />STATEMENT OF OPPOSITION <br />1. Name, mailing address, and telephone number(s) of Objectors: <br />Tierra Hermosa, LLC <br />2301 North Greenville Avenue, Suite 150 <br />Richardson, Texas 75082 <br />(972) 644 -3167 <br />2. State facts as to why the Application should not be granted or why it should be granted only in part <br />or on certain conditions: <br />a. Objector owns water rights in the Animas River. The Objector maybe materially injured if <br />the application is granted without appropriate protective terms and conditions. <br />b. The application does not propose protective terms and conditions sufficient to insure that the <br />proposed uses of water right will not injure the Objector's water rights. <br />c. The applicant must meet its burden of proof with respect to each element of its claims, <br />including ownership of or right to use each water right and structure described in the application. In <br />addition, the applicant must be held to strict proof that the right to add or change uses not previously decreed <br />will not be injurious to the Objector's water rights. <br />d. The application contains insufficient information to enable the Objector to determine whether <br />other grounds for objection exist. The Objector therefore reserves the right to state further grounds for <br />objection when more information is available. <br />e. The Objector's Statement of Opposition is continuing in nature and shall apply equally to any <br />amended application that may be filed herein, so that the filing of a separate Statement of Opposition to any <br />such amended application shall not be necessary. <br />