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FIFTH AFFIRMATIVE DEFENSE <br />Plaintiffs' claims are barred or limited by equitable estoppel, laches or waiver. <br />SIXTH AFFIRMATIVE DEFENSE <br />WFC's activities complied with and were required by WFC's mining permit, which <br />properly implemented all applicable requirements. <br />SEVENTH AFFIRMATIVE DEFENSE <br />Plaintiffs' alleged damages are speculative, remote, imaginary, or impossible of <br />ascertainment. <br />EIGHTH AFFIRMATIVE DEFENSE <br />Plaintiffs JoEllen Turner and Michael Morgan lack standing to bring this action due to <br />their invalid or subordinated interest in the subject property. <br />WFC's PRAYER FOR RELIEF <br />WHEREFORE, WFC prays for an Order of this Court entering judgment on its behalf <br />and awarding its damages, costs, and attorneys' fees, in addition to such further relief as the <br />Court shall deem proper. <br />Respectfully submitted this 18`h day of April, 2011. <br />CARVER SCHWARZ McNAB & BAILEY, LLC <br />Duly executed original on file <br />Christopher Kamper ( #24629) <br />Craig R. Carver ( #5200) <br />Attorneys for Defendant <br />Filed electronically. See C.R. C.P. 121 § 1 -26 Original in file <br />100047771.11 4 <br />