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Case No. 3345 Fourth Amended Complaint and Related July 24 1942
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Case No. 3345 Fourth Amended Complaint and Related July 24 1942
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Water Supply Protection
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Case No. 3345 Fourth Amended Complaint and Related July 24 1942
State
CO
Date
7/24/1942
Author
Boyle, John; Stienmeyer, E.; Rush, William
Title
Case No. 3345 Fourth Amended Complaint and Related July 24 1942
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if .(l <br />4. That it affirmatively appears from the allegations <br />contained in said further and second cause of action that the relief <br />sought therein is barred by the provisions of Chapter 90, Sections <br />152 and 153, CSA 1935 (C.L. 1921, Sections 1754 and 1755). <br />And defendants further move the Court to enter an order <br />herein dismissing the further and third cause of action, set forth <br />in Plaintiff's fourth amended complaint herein, upon the grounds <br />and for the reasons; <br />1. That this Court has no jurisdiction of the subject <br />matter involved in said further and third cause of action. <br />2., That this Court has no ,jurisdiction of the person of <br />the real parties in interest, whose rights are involved in said <br />further and third cause of action. <br />3. That the said further and third cause of action fails <br />to state any claim upon which the relief sought therein, or any <br />relief, can be granted. <br />4. That it affirmatively appears from the allegations <br />contained in said further and third cause of action that the relief <br />sought therein is barred by the provisions of Chapter 90, Sections <br />152 and 153, CSA 1935 (G.L. 1921, Sections 175+ and 1755). <br />And defendants further move the Court to enter an order <br />herein dismissing the.further and fourth cause of action, set forth <br />in Plaintiff's fourth amended complaint filed herein, upon the <br />grounds and for the reasons: <br />1. That this Court has no jurisdiction of the subject <br />matter involved in said fourth cause of action. <br />2. That this Court has no jurisdiction of the person of <br />the real parties in interest, whose rights are involved in said <br />fourth cause of action. <br />3. That the venue, or place of trial, of the matters in <br />controversy, set forth in said fourth cause of action, is improperly <br />lodged in the District Court of Chaffee County, Colorado; in that, <br />the venue, or place of trial, of any controversy as to priorities <br />of the right to use of water in Water District No. 14 is exclusively <br />lodged and fixed by law in the District Court of Pueblo County, <br />Colorado; and the venue, or place of trial, of any controversy as to <br />priorities of right to the use of water in Water Districts Nos. 17 <br />and 67 is exclusively lodged and fixed by law in the District Court <br />of Bent County, Colorado. <br />4. That the said fourth cause of action fails to state <br />any claim upon which the relief sought therein, or any relief, can <br />be granted. <br />5. That it affirmatively appears from the allegations <br />contained in said first cause of action that the relief sought <br />therein is barred 'by the provisions of Chapter 90, Sections 152 and <br />153, CSA 1935 (C.L. 1921, Sections 1754 and 17 ,95). <br />And defendants further move to dismiss the further and <br />fifth cause of action, as set forth in Plaintiff's fourth amended <br />complaint filed herein, upon the grounds and for the reasons: <br />1. That this Court has no jurisdiction of the subject <br />matter involved in said fifth cause of action. <br />2. That this Court has no jurisdiction of the person of <br />the real parties in interest, whose rights are involved in said <br />fifth cause of action. <br />3. That the venue, or place of trial, of the matters in <br />controversy, set forth in said fifth cause of action herein, is <br />improperly lodged in the District Court of Chaffee County, Colorado; <br />—2— <br />
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