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<br />51. At the request of More, Halsnes conducted and secured the necessary diligence, surveys, <br />inspections, studies and other feasibility measures; sought the necessary approvals, and secured a <br />third party operator for the subject gravel operation. <br />52. With full knowledge of Halsnes' services and expectation of payment therefore by virtue <br />of the Lease/Purchase Option, More appreciated and accepted a substantial benefit from Halsnes' <br />services, including but not limited to surveys, engineering, reserve studies and the imminent <br />approvals, <br />53. More has failed to pay Halsnes for his work and efforts. <br />54. Under the circumstances set forth above, and more specifically since More agreed that <br />Halsnes would have the right to seek county approvals but More terminated that right before <br />Halsnes could finish prosecuting the application, More's actions in retaining the benefits of <br />Halsnes' efforts without payment of its value is entirely unjust and inequitable. <br />WHEREFORE, Halsnes prays for judgment against More in an amount to be determined <br />at trial, for actual, consequential damages, costs, reasonable attorneys' fees and interest as <br />provided by law, and for such other and further elief that the Court deems just and proper. <br />Respectfully submitted this ~ day of , 2001. <br />BE L F ~f P.C. <br />By: <br />Edward M. Bendelow, E ~teg. No. 1883 <br />Alan M. Keeffe, Esq., Re . o. 15090 <br />Nicole Y. Pieterse, Esq., Reg. No. 26216 <br />ATTORNEYS FOR PLAINTIFF <br />JARLE HALSNES <br />Plaintiff s Address: <br />P.O. Box 774623 <br />Steamboat Springs, CO 80477 <br />