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2012-02-21_APPLICATION CORRESPONDENCE - C2010089 (11)
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2012-02-21_APPLICATION CORRESPONDENCE - C2010089 (11)
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Last modified
8/24/2016 4:48:49 PM
Creation date
2/24/2012 9:25:55 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C2010089
IBM Index Class Name
Application Correspondence
Doc Date
2/21/2012
Doc Name
Preliminary Adequacy Review No. 3 (Part 3 of 3)
From
Western Fuels Association Inc
To
DRMS
Email Name
MLT
SB1
Media Type
D
Archive
No
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If to WFC: <br />11 <br />Western Fuels- Colorado <br />P.O. Box 33424 <br />Denver, CO 80233 <br />With a copy to: <br />Peter Lucas, Esq. <br />Appel & Lucas, P.C. <br />1917 Market Street <br />Denver, Colorado 80202 <br />11. Successors and Assigns. Subject to provisions of Section 9 above, this Agreement shall <br />be binding upon and inure to the benefit of the parties hereto and their respective successors and <br />assigns. <br />12 Specific Performance. In addition to any other available remedies, any party may obtain <br />specific performance of this Agreement, without regard to whether any adequate remedy at law <br />exists. <br />13 Dispute Resolution. Except as modified by paragraph 14.1 any claim or dispute arising <br />out of or relating to this Agreement shall be subject to arbitration. A dispute shall be submitted <br />to three arbitrators; one to be chosen by CCC, one to be chosen by WFC, and the final arbitrator <br />to be chosen by agreement of the other two arbitrators. Unless the parties agree otherwise; (i) <br />the arbitration shall be conducted in accordance with the Colorado Uniform Arbitration Act, <br />Section 13 -22 -201 et seq., C.R.S.; (ii) discovery shall be permitted in accordance with <br />guidelines set by the arbitrators; and (iii) all hearings shall take place in Grand Junction, <br />Colorado. Any demand for arbitration shall be made within a reasonable time after the claim or <br />dispute has arisen, and in no event shall it be made after the date when institution of legal or <br />equitable proceedings based on such claim or dispute would be barred by the applicable statute <br />of limitations. Any award rendered by the arbitrator or arbitrators shall be final, and judgment <br />may be entered upon such award in accordance with applicable law in any court having <br />appropriate jurisdiction. <br />13.1 Any dispute related to the Relocation Plan or the Construction Design Plans shall <br />be arbitrated before a single arbitrator who shall be a professional engineer knowledgeable in <br />the design and construction of pipeline projects. The arbitrator shall be selected by a <br />professional engineer hired by WFC and a professional engineer selected by CCC. <br />13.2 In the event an acceptable arbitrator cannot be selected pursuant to paragraphs 14 <br />or 14.1, either party may apply to a court of competent jurisdiction to appoint an arbitrator. <br />
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