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303 6595223 P, 12 <br />extract, pzocess, sell, use and remove material during the term of the lease. <br />46. The Defendants Chavets in this case knew about the contract between the Plaintiff <br />and Lafarge because they were present doting public hearings, which resulted in public records <br />of the agreement, because the Plaintiff disclosed information regarding the contract to <br />Defendants Chavers, and because of the physical inspection of the Defendants Chavers' <br />property, at which time the Defendants Chavers would have observed Lafarge's company trucks <br />on the property. <br />47. Because the Defendant is refusing the Plaintiff access to the easement, a request has <br />been made not to allow any water to run through the area. Lafarge has stated that until the <br />Plaintiff resolves the issue with the Defendant, thew is to be no more dischazge'of any water <br />from the site, including any irrigation water. As a result, water is pooling and there is some <br />concern that this will erode the banks and walls of the highway. Lafarge has ceased certain <br />operations until the dispute is settled: <br />48. Defendants Chavers' interference with the contract between the Plaintiff and <br />Lafarge is improper because discharge of water, including water used for irrigation purposes, has <br />ceased. Because Lafazge is responsible for discharge according to the permit, they have decided <br />that ao discharge of any water, including irrigation water, is to leave the site. <br />49. The Defendants Chavers' interference with the contract between the Plaintiffs and <br />Lafarge will cause the Plaintiffs damages.and losses because Lafarge is bringing a suit against <br />the Plaintiffs claiming breach of contract. The Defendants are intentionally interfering with the <br />contzachial obligation between the Plaintiff and Lafarge. <br />WHEREFORE, Plaintiffs respectfully request this Court to grant the following relief; <br />a. Enter an order enjoining the Defendants from restricting the Plaintiffs' <br />tight to access the Porter Seepage Ditch and the Ogilvie Seepage Ditch; <br />b. Enter an order declaring that the Plaintiffs have a right to the ditch for the <br />transportation of water to and from the Platte River in accordance with recorded documents; <br />c. Enter an order allowing Plaintiffs to recover its attorney fees and costs; <br />d. Enter an order allowing Plaintiffs to recover damages; <br />e. Enter an order to quiet title in favor of the Plaintiffs; and <br />g. ,Afford such other relief as may be proper. <br />