Laserfiche WebLink
14. PR -06 speaks for itself. Defendant admits that the entire subject property will be <br />reclaimed as Prime Farmland, but denies the implication that all of the land historically qualified <br />as Prime Farmland, and affirmatively states that the administrative record demonstrates that <br />approximately 30% of the property was not Prime Farmland prior to the commencement of <br />mining activities on the property. <br />15. PR -06 speaks for itself. <br />16. Defendant is without knowledge or information sufficient to admit or deny the <br />allegations of paragraph 16 of the Complaint, and on that basis denies them. <br />17. PR -06 speaks for itself, but this particular paragraph is notably inaccurate. <br />18. Deny, including each and every subpart. <br />19. There is no paragraph 19 of the Complaint. <br />20. Deny, including each and every subpart. <br />21. Deny. <br />22. Admission or denial of the allegations of paragraph 22 is not required, therefore <br />defendant denies any factual allegations contained therein, to the extent there are any. Defendant <br />denies the implication that the acts requested by plaintiffs are required by law. <br />23. Each and every allegation not specifically admitted in paragraphs 1 to 22 of this <br />Answer above is denied. <br />24. Defendant denies that plaintiffs are entitled to any relief. <br />AFFIRMATIVE DEFENSES <br />FIRST AFFIRMATIVE DEFENSE <br />Plaintiffs fail to state a claim based on which relief can be granted. <br />SECOND AFFIRMATIVE DEFENSE <br />Plaintiffs' claims are barred or limited by applicable statutes of limitations. <br />THIRD AFFIRMATIVE DEFENSE <br />Some or all of Plaintiffs' claims are barred by their failure to exhaust administrative <br />remedies. <br />FOURTH AFFIRMATIVE DEFENSE <br />Plaintiffs' claims are barred or limited by express contractual waiver and other express <br />terms that constitute a covenant not to sue. <br />{00047771.1 ) <br />