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ANSWER TO PLAINTIFFS' CLAIMS FOR RELIEF <br />11. In cesponse to Paragraph 11 of the Complaint, Clear Creek incorporates its <br />responses to Paragraphs 1 through 10 of the Complaint, as though fully set forth herein. <br />12. In response to Paragraph 12 of the Complaint, Clear Creek denies that the <br />Plaintiffs have been adversely affected or aggrieved by the action of the MLRB. Clear Creek <br />denies that the Plaintiffs are entitled to any relief pursuant to C.R.S. § 24-4-106(4) for the <br />reasons set forth in this Answer, or for any other reason. <br />12.A. In response to Paragraph 12.A. of the Complaint, Clear Creek denies the first <br />sentence of that paragraph. Clear Creek admits that the Waste Water Treatment Plant is a <br />significant, valuable and permanent manmade structure. Clear Creek lacks knowledge or <br />information whether the Plaintiff City of Black Hawk holds a direct financial interest in the <br />Waste Water Treatment Plant, and so denies that allegation. Clear Creek denies all other <br />allegations of Paragraph 12.A. Clear Creek avers that the last sentence of Paragraph 12.A. of the <br />Complaint states a legal conclusion. <br />12.B. In response to Paragraph 12.B. of the Complaint, Clear Creek denies all of the <br />allegations of that Paragraph. <br />12.C. In response to Paragraph 12.C. of the Complaint, Clear Creek denies all of the <br />allegations of that paragraph. <br />12.D. In response to Paragraph 12.D, of the Complaint, Clear Creek admits that the City <br />of Black Hawk has "decreed water rights." Clear Creek denies the remaining allegations of <br />Paragraph 12.D. of the Complaint. <br />12.E. Clear Creek denies the allegation of the first sentence of Paragraph 12.E. of the <br />Complaint. Clear Creek denies the allegations of the second sentence of Paragraph 12.E. of the <br />Complaint, because it Tacks information sufficient to ascertain their truth. <br />13. Clear Creek denies all allegations of Paragraph 13 of the Complaint. <br />13.A. In response to Paragraph 13.A. of the Complaint, Clear Creek admits that its <br />application stated it would seek necessary Gilpin County permits. Clear Creek denies the <br />remaining allegations of Paragraph 13.A. of the Complaint. <br />13.B. In response to Paragraph 13.B. of the Complaint, Clear Creek admits that its <br />application stated it would seek necessary Gilpin County permits. Clear Creek denies the <br />remaining allegations of Paragraph 13.B. <br />13.C. In response to Paragraph 13.C. of the Complaint, Clear Creek denies all of the <br />allegations of that paragraph. <br />3 <br />