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not removeable. Barkers' conclusory allegations do not establish jurisdiction, and <br />Barkers have not alleged any facts to establish their assertion that the amount in <br />controversy exceeds $75,000. <br />WHEREFORE, Empire respectfully requests that the Court remand this action to <br />the District Court for Moffat County, State of Colorado. Empire further requests that <br />the Court award Empire its costs and expenses, including attorneys fees, incurred as a <br />result of the removal, pursuant to 28 U.S.C. § 1447(c). <br />Empire requests that the Court hold oral argument to address the issues raised by <br />this motion. <br />Pursuant to D.C.COLO.LCivR 7.1, counsel for Empire conferred with counsel <br />for Barkers in an effort to resolve this matter, but counsel for Barkers stated that <br />Barkers would not consent to this Motion. <br />Dated Octoberr~2004 <br />Respectfully submitted, <br />ROBE T A. BASS , #12719 <br />HOLLAND BL HART LLP <br />8390 East Crescent Parkway <br />Suite 400 <br />Greenwood Village, CO 80111-2800 <br />ATTORNEYS FOR PLAINTIFF <br />-8- <br />