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soils' classification as prime farmland is dependent upon other relevant factors not stated in the <br />Amended Complaint. <br />13. WFC denies the allegations of paragraph 13 of the Amended Complaint, and <br />affirmatively states that the allegation of 190,000 tons of soil removed is incorrect and is lacking <br />any good faith basis in fact. <br />14. WFC denies the allegations of paragraph 14 of the Amended Complaint and <br />affirmatively states that it provided a complete soil survey to DRMS in 1998, showing clearly the <br />presence, location, and classification of Barx soils on the Premises. <br />15. WFC denies the allegations of paragraph 15 of the Amended Complaint. <br />16. WFC denies the allegations of paragraph 16 of the Amended Complaint. <br />17. WFC denies the allegations of paragraph 17 of the Amended Complaint. <br />18. WFC denies the allegations of paragraph 18 of the Amended Complaint. <br />19. WFC denies the allegations of paragraph 19 of the Amended Complaint. <br />20. WFC denies the allegations of paragraph 20 of the Amended Complaint. <br />21. WFC denies the allegations of paragraph 21 of the Amended Complaint. <br />22. WFC denies the allegations of paragraph 22 of the Amended Complaint. <br />PLAINTIFFS' PUTATIVE LEGAL CLAIMS <br />CLAIM ONE — ALLEGED BREACH OF CONTRACT <br />23. WFC incorporates its responses to paragraphs 1 through 22 of the Amended <br />Complaint as previously stated in reference to each such paragraph. <br />24. The allegations of paragraph 24 of the Amended Complaint contain a legal <br />conclusion, and WFC therefore denies them. <br />25. WFC denies the allegations of paragraph 25 of the Amended Complaint. <br />26. WFC denies the allegations of paragraph 26 of the Amended Complaint. <br />27. The allegations of paragraph 27 of the Amended Complaint contain a legal <br />conclusion and speculation as to the facts, WFC therefore denies them. <br />CLAIM TWO — ALLEGED VIOLATION OF COLORADO SCMRA <br />28. WFC incorporates its responses to paragraphs 1 through 27 of the Amended <br />Complaint as previously stated in reference to each such paragraph. <br />{00020579.2 1 <br />