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06-05-2006 02:39PM FR011-DOL NATURAL RESOURCES <br />3036663553 T-5T2 P.011/02T F-633 <br />extract, process, sell, use and remove material during the term of the lease. <br />4b. The Defendants Chavers in this case knew about the contract between the Plaintiff <br />and Lafarge because they were present during public hearings, which resuhed is public rewrds <br />of the agreement, because dta Plaintiff disclosed information tsgarding the contract to <br />Defendants Cbavers, and because of th;physical inspcclion of the Defendants Chavers' <br />property, at which tithe the Defendanu Chaveis would havo observed Lafarge's company trucks <br />on the property. <br />47. Beoause the Defendant is refusing the Plainti$access to the aasartteat, a requesK has <br />bean made sot to allow say Water to run through the arcs. Lafarge has stated that ttrttil the <br />Plaintiff reaolvts the issue with the Defendant, there is to be no more discharge of say water <br />from the sits, including any irrigation water. As a result, water is pooling and there is soma <br />concern that this will erode the banks and walls of the highway. Lafarge has ceased certain <br />oprratioas until the dispute is settled. <br />48. Defendants Chavers' interference wish the contract between the Plairttrff and <br />Lafarge is improper because discharge of water, including water used far irrigation purposes, has <br />ceased, Because Lafarge is responsible for discharge recording to the permit, they have decided <br />that no discharge of any water, including irrigation water, is to leave the site. <br />49. The Defendants Chavars' interference with the contract between the Plaintiffs and <br />Lafarge will cause the Plaintiffs datttages, and lasses because Lafarge is brirtgiag a suit against <br />the Plaintii~•§ claiming breach of coatraci The Defendants are inteatianally interfering with the <br />contractual obligatiott between the Plaintiff and Lafarge. <br />WHEREFORE, Plaintiffs respectfully request this Court to gram the following relief <br />a. Enttr an order enjoitring the Defendants from restricting the Plaintiffs' <br />right to access the Parser Seepage Ditch and the Ogilvie Seepage Ditch; <br />b. Eater as order declaring that the Plaintiffs have a right to the ditch far the <br />transportation of water to and finra the Platte River in accordance with recorded doctuneats; <br />c. Fatter an order allowing Plaintiffs to recover its attorney fees and sorts; <br />d. Eater an order allowing Plaintifrs to recover datuages; <br />e. Eater an order to quiet title in favor of the Plaintiffs; and <br />g. Afford such other relief as may be proper. <br />