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(Deposition of James Tatum) <br />1 think you are ultimately entitled to three CFS of <br />2 water out of Consolidated Ditch? <br />3 A. No. It's our contention that we are <br />4 entitled to one CFS out of the Consolidated Ditch. <br />5 Q. First page of your disclosure <br />6 certificates or certificate where you mention the <br />7 plaintiffs' claim that in 1990 and 1991 plaintiffs <br />8 allowed defendant to take a portion of plaintiffs' <br />9 land and construct roads, electric power lines and <br />10 equipment for a fourteen-foot tunnel, and just what <br />11 does that refer to? <br />12 A. A fourteen-foot tunnel, the air shaft. <br />13 Q. You are talking about the surface part <br />14 of it? <br />15 A. It's a hole in the ground fourteen feet <br />16 in diameter. <br />17 Q. "Plaintiffs claim that the <br />18 consideration from the defendant was two CFS on the <br />19 South Fork of Purgatoire River." Now, is that in <br />20 addition to the one CFS? <br />21 A. No. I maintained that we are entitled <br />22 to one CFS. <br />23 Q. As a result of the ventilation shaft <br />24 agreement? <br />25 A. No. I felt like we were entitled -- we <br />MEEK & ASSOCIATES <br />3016 3rd Ave., Pueblo, Co 81008 (719) 542-1010 <br />34 <br />