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TH11tD CLAIM FOR RELIEF <br />(TRESPASSj(NUISANCE) <br />15. Chavers incorporates paragraphs 1 through 14 in its First and Second Claim for <br />Relief and in this Third Claim for Relief. <br />16. Chavers incorporates paragraphs 1 through 14 in its First Claim for Relief and <br />Second Claim for Relief in this Third Claim for Relief. <br />17. The wrongfirl acts of TKO in their failure to maintain their land so as to prevent <br />water flow end discharge upon Chavers land constitute a trespass and nuisance which should be <br />abated, and further from which has damaged Chavers and will continue to damage Chavers in an <br />amount to be determined at trial. <br />FOURTH CLAIM FOR RELIEF <br />(SLANDER OF TITLE) <br />18. Chavers incorporates paragraphs 1 through 17 in its First, Second and Third Claim <br />for Relief and in this Fourth Claim for Relief. <br />19. The Plaintiffs have improperly and illegally placed a Gs pendes upon the property <br />of Chavers thus slandering the title of Chavers resulting in the interference and prohibition of <br />Chavers in the sale of their property for which negotiations are ongoing, resulting in damage to <br />Chavers in an amount to be determined at trial. <br />VVI~REFORE, Defendant's respectfully requests this Court to dismiss Plaintiffs' <br />Complaint, grant attorney's fees and costs, enter judgement in the nature of injunctive relief for <br />Chavers and enter judgement for damages on behalf of Chavers, attorney's fees, court costs, <br />interest and such other and further relief as the Court may deem just and proper. <br />Dated thisl~ day of , 2006. <br />6 <br />