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29. WFC admits the allegations of paragraph 29 of the Amended Complaint. <br />30. WFC denies the allegations of paragraph 30 of the Amended Complaint. <br />31. WFC denies the allegations of paragraph 31 of the Amended Complaint, and <br />affirmatively states that since reclamation is not complete and will not be complete until the year <br />2022, Plaintiffs' allegations consist of mere speculation. <br />32. WFC denies the allegations of paragraph 32 of the Amended Complaint. <br />33. WFC denies the allegations of paragraph 33 of the Amended Complaint. <br />34. WFC does not respond herein to Plaintiffs' jury demand, which appears to contain <br />no factual allegations. <br />35. Each and every allegation not specifically admitted in paragraphs 1 to 34 of this <br />Answer to First Amended Complaint above is denied. <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 />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 />{00020579.2 1 4 <br />