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56. The Division has insufficient knowledge and information to form a belief as to <br /> the allegations of paragraph 56 and therefore denies the same. <br /> 57. The Division admits that it has begun a project known as the Huntsman Project <br /> but denies the rest of the allegations in paragraph 57. <br /> 58. The Division denies the allegations of paragraph 58. <br /> 59. Except as otherwise specifically admitted herein, the Division denies each and <br /> every allegation of the Amended Third Party Complaint. <br /> AFFIRMATIVE DEFENSES <br /> 60. The Amended Third-Party Complaint fails in whole or part to state a claim upon <br /> which relief can be granted. <br /> 61. The Third-Party Plaintiffs have failed to join indispensable parties as required by <br /> C.R.C.P. 19. <br /> 62. The Third-Party Plaintiffs have failed to exhaust administrative remedies. <br /> 63. The Amended Third-Party Complaint is barred in whole or in part by waiver, <br /> estoppel and\or laches. <br /> 64. The Third-Party Plaintiffs have failed to mitigate alleged damages. <br /> 65. This Court lacks jurisdiction to hear all or part of the claims asserted in the <br /> Amended Third-Party Complaint. <br /> 66. The Third-Party Plaintiffs' claims are barred in whole or in part by the Colorado <br /> Governmental Immunity Act. <br /> 67. The Third-Party Plaintiffs' claims are barred in whole or in part by applicable <br /> statutes of limitations. <br /> 7 <br />