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GENERAL53971
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Last modified
8/24/2016 8:39:21 PM
Creation date
11/23/2007 9:07:33 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2004078
IBM Index Class Name
General Documents
Doc Date
7/10/2006
Doc Name
Andrew Chavers-Ditch Rights
From
James K. Kreutz & Associates
To
DMG
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
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ANSWER <br />1. These Defendants, Chavers, are without sufficient information or knowledge to <br />admit as to the allegations wntained in paragraphs 1 of Plaintiffs Complaint and therefore deny <br />same. <br />2. Chavers deny the allegations contained in paragraph(s) 2 and 3 of Plaintiffs <br />Complaint. <br />3. Chavers deny the allegations contained in paragraphs 4 and 5 of Plaintiffs' <br />Complaint and without waiving such denial Chavers specifically derry e~dstence of any ditches that <br />are referred to in such allegations or associated easements, and specifically deny that any such <br />ditches or associated easements run with the land. Chavers further specifically deny any such <br />ditches allow Plaintiffs' to transport water through the ditch across Highway 85 and onto Chavers <br />property. <br />4. Chavers deny the allegations contained in paragraph 6 of Plaintiffs' Complaint and <br />without waiving such denial admit Plaintiffs' wrongfully allowing water to seep from their land <br />onto Chavers land and that Chavers has a right to prevent such trespass and damage caused by the <br />wrongful acts of these Plaintiffs'. Chavers specifically denies obstructing pathways and restricting <br />water from reaching the South Platt River since there is no pathway across Chavers land to the <br />South Platt River and never has been. <br />5. Chavers deny the allegations contained in paragraph 7 of Plaintiffs' Complaint and <br />without waiving such denial admit that Colorado Departmem of Transportation ("CDOT") have <br />attempted to restrict the wrongful diversion of water from Plaintiffs' land to Chavers land through <br />that land of CDOT. <br />6. Chavers admit as to venue and jurisdiction and otherwise deny the allegations <br />contained in paragraph(s) 8 through 13. <br />7. Chavers deny the allegations contained in paragraph(s) 14, 15, 16, 17, 18, 19 and <br />20 of Plaintiff a Complaint. Without waiving such denial admit that they have horses on their <br />property and deny that TKO has done anything in order to protect such horses and property but in <br />fact quite the contrary, have taken action so as to allow water and silt to go upon the land of <br />Chavers containing certain pesticides, insectiades, and other injurious material to the animals of <br />Chavers for which Chavers have had to displace such animals from their property as a result of the <br />wrongful acts of TKO. <br />8. Chavers deny the allegations contained in paragraph 21of TKO's Complaint. <br />
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