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I DISTRICT COURT, LA.S ANIMAS COUNTY, STATE OF COLORADO <br />CASE NO. 92-CV-127 <br />PLAINTIFF'S SECOND AMENDED ORIGINAL COMPLAINT <br />JAMES (JIM) and ANN TATUM, <br />Plaintiffs, <br />vs. <br />WYOMING FUEL COMFANY and <br />BASIN RESOURCES, INC. <br />Defendants. <br />COMES NOW, JIM and ANN TATUM, Plaintiffs herein, and <br />files this their Second Amended original Complaint, and in <br />support hereof would show the Court and Jury: <br />PARTIES. JURISDICTION AND VENUE <br />1. Plaintiffs and Defendants are both land owners in Las <br />Animas County, Colorado. Plaintiffs and Defendants are also <br />~ owners of certain. water rights on the Purgatorie River in <br />Las Animas County, Colorado. <br />2. Defendant BASIN RESOURCES has been served and their <br />answer is on file with the Court. <br />3. No service is needed on WYOMING FUEL COMPANY at this <br />time. <br />~ BACKGROUND FACTS <br />4. Tatums inco-porate by reference herein the allegations <br />set forth in paragraphs 1 through 3 above. <br />5. The actual ownership of property owned by BASIN <br />RESOURCES may or may not be in the name of a subsidiary <br />corporation or in the name of an alter-ego company. It is <br />believed that Basin Resources, Inc., is the record owner of <br />i the Las Animas County property formerly owned by WYOMING <br />~ FUEL COMPANY at~d that BASIN RESOURCES, INC. has assumed all <br />legal liability in this matter that WYOMING FUEL COMPANY <br />might have in *he matter. <br /> <br />