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REV103394
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REV103394
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Entry Properties
Last modified
8/25/2016 1:14:13 AM
Creation date
11/22/2007 1:05:56 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981044
IBM Index Class Name
Revision
Doc Date
11/18/2004
Doc Name
November 2004 Status Report Barker Lawsuit
From
BTU Empire Corporation
To
DMG
Type & Sequence
RN4
Media Type
D
Archive
No
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Thus, the Barkers have failed to meet their burden to support their assertion that <br />the amount in controversy requirement is met in this case. <br />II. THE AMOUNT IN CONTROVERSY IS LESS THAN $75,000 <br />Where a plaintiff seeks declaratory relief, "the amount in controversy is <br />measured by the value of the object of the litigation." Hunt v. Washington State Apple <br />Advertising Comm'n, 432 U.S. 333, 347 (U.S. 1977). Where a plaintiff seeks injunctive <br />or equitable relief related to possession of property, "the amount in controversy is the <br />value of the realty directly affected." Sanchez v. Taylor, 377 F.2d 733, 736 (10th Cir. <br />] 967)(seeking declaratory order to quiet title); A.C. McKoy, Inc. v. Schonwald, 341 <br />F.2d 737, 739 (10th Cir. 1965); Ronzio v. Denver & R.G.W.R. Co., 116 F.2d 604, 606 <br />(10th Cir. 1940). The court may examine the value of the interest from the perspective <br />of either the plaintiff of the defendant. Ronzio, 116 F.2d at 606. <br />Here, the "object of the litigation" is a right of entry. Empire is seeking <br />recognition that it has a limited right of entry onto the Property to perform reclamation <br />that it is required to do under the Act. On 638 acres of the Property, this involves only <br />observing whether any significant additional surface subsidence occurs as a result of <br />underground mining that ceased more than 15 years ago (Complaint, Q16). On two <br />acres of the Property this reclamation involves only monitoring the growth of <br />vegetation previously planted and repairing any surface erosion (Complaint, ¶17). <br />Empire's Complaint, at Exhibit B, demonstrates that Empire's determination of <br />the reasonable value for leasing the right of entry would be no greater than $7,000 <br />annually for the entire 640 acres of the Property, and that this value would decrease to <br />-6- <br />
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