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(Deposition of James Tatum) <br />1 A. I think we were supposed to get one CFS <br />2 for one point five CFS. <br />3 Q. But up on the South Fork? <br />4 A. Yes. <br />5 Q. Was that supposed to be a permanent <br />6 arrangement in your mind or was that a one-year <br />7 situation? <br />8 A. Permanent trade. I need that water <br />9 permanently on that acreage down there and they <br />10 could use the water out of Nine anywhere on the <br />11 Middle Fork. <br />12 Q. With whom did you enter into that <br />13 agreement? <br />14 A. I believe Robin Forte. I think it was <br />15 -- one reason I'm saying it must have been Robin <br />16 Forte is because I recall the deposition testimony <br />17 of Ernie Trujillo, saying at that time that he was <br />18 employed by Wyoming Fuel, and Robin Forte told him, <br />19 if I recall his testimony, verbatim, here in this <br />20 room, Ernie Trujillo said, "Robin Forte told me to <br />21 go ahead and give Tatum. Tatum has water. We have <br />22 made a deal." <br />23 Q. Is this alleged agreement some part of <br />24 your complaint in this case? <br />25 A. It is the beginning of the agreement <br />MEEK & ASSOCIATES <br />3016 3rd Ave., Pueblo, Co 81008 (719) 542-1010 <br />31 <br />