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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 assert claims against WFC <br />due to their invalid or subordinated interest in the subject Premises. <br />NINTH AFFIRMATIVE DEFENSE <br />Plaintiffs First Claim for Relief is barred or limited by claim preclusion doctrines <br />including collateral attack, collateral estoppel, and res judicata. <br />TENTH AFFIRMATIVE DEFENSE <br />Plaintiffs Second Claim for Relief is barred because the DRMS took appropriate <br />enforcement action in response to the Notice given by Plaintiffs. <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 10`h day of February, 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 />{00020579.2 } <br />