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PERMFILE123728
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PERMFILE123728
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Entry Properties
Last modified
8/24/2016 10:21:26 PM
Creation date
11/25/2007 11:49:17 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2005080
IBM Index Class Name
Permit File
Doc Date
9/1/2006
Doc Name
Motion to Dismiss
From
Objectors Attorney
To
MLRB
Media Type
D
Archive
No
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08/09/2006 14:10 7190360200 m IiARTSFpRN PAGE 04/06 <br />] 1. There may be persons interested in the subject matter of this action whose names cannot <br />be inserted herein because said names ata unknown to the Plaintiff, although diligent <br />efforts have been made to ascertain the names of said persons. Said persons have been <br />made Defendants and designated as °all unknown persons who may claim any interest in <br />the subject matter of this action"; insofar as Plaintiffs' knowledge extends, the interest, ]f <br />any, of the tmimown parties is derived through one or mote of the named Defendants. <br />12. 'The Defendants may claim some right, title or interest in and to the.above-described . <br />mirxral interests in said real property adverse to the Plaiatii~ the claims of said <br />Dcfendatts are without foundation m right <br />WH$IItE1FORE, the Plaimiffs pray for complete adjudication of the rights of all parties to this <br />action with respect to one~talf of all the oil, gas, and other minerals, including sand and gravel, <br />in the real property hereinabove desen"bed; for a Decree requiring the Defendants to sat forth the <br />nature of thew c]aims,.detcrmining that the Defendants, and each of them, have no interest, estate <br />or claim of any kind whatsoever in or to the aboveā¢deseribed mineral interest in the above <br />described real property, forever carting and enjoining the Defendants from ever asserting any <br />claim or title thereto, quieting the title of the Plaintiffs in and to the above-described mineral <br />interest in said real property, and adjudging that the Plaintiff Cargill is the owner in fee simple <br />and is entitled to possession of one-half of all the oil, gas, and other minerals, including sand and <br />gravel, in the real property hereinabove described in Exhibit A, and the Plaintiff Neighbors. for a <br />Desirable Park County, Inc., is, the owner in fee simple and is entitled to possession with respect <br />to one-half of all. the.oit, gas, and other minerals, including send and gravel, in the real property <br />hereinabove described in lraragrnph 3 above; and for such other and further relief as the Court <br />may deem just and proper. <br />Itespectfnllq submitted this ~ day of ~r'~'f 2006. <br />I:d Hartshorn <br />ATTORNEY FOR PLAINTIFF <br />ADDRESS OF PL.~INTIFF: <br />'Neighbors for a Desirable Park County, Inc. <br />P. O. Hox 43 <br />Fairpiay, CO 80440 <br />
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