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77. In order to access the Barkers' lands for the purposes enumerated <br />in the contracts between the Barkers and these third parties, the third parties <br />must use the historic access route to the Barkers' lands and/or the Moffat County <br />road that the County has allowed Empire to use as a haul road. <br />78. By denying these third parties the right to use the historic access <br />route and/or the Moffat County road that the County has allowed Empire to use <br />as a haul road as a means to access the Barkers' lands, Empire has precluded, <br />and is precluding, these third parties (and each of them) from exercising their <br />contractual rights to use the Barkers' ]ands in the ways described in their leases <br />with the Barkers. <br />79. By denying these third parties access to the Barkers' lands via the <br />historic access route and/or the Moffat County road that the County has allowed <br />Empire to use as a haul road, Empire is interfering with the contractual <br />relationship between the Barkers and these third parties (and each of them). <br />80. Money damages have resulted, and may result in the future, to the <br />Barkers and to their third party lessees as a result of Empire's interference with <br />the contractual relationships between the Barkers and such third party lessees <br />occasioned by Empire's refusal to allow such third party lessees to access the <br />Barkers' lands via the historic access route and/or the Moffat County road that <br />the County has allowed Empire to use as a haul road. <br />WHEREFORE, the Barkers respectfully request the following relief <br />against Empire: <br />12 <br />