Laserfiche WebLink
counsel, met several times to discuss various issues. In addition, Division members met <br /> several more times with representatives of the Third-Party Plaintiffs. <br /> During this time, the Division obtained bids for, and undertook, reclamation planned <br /> for this season. Also during this time, the Division provided extensive information to the <br /> Third-Party Plaintiffs about what reclamation work would be accomplished this year and <br /> when the reclamation projects would begin. Thus, the Third-Party Plaintiffs were well aware <br /> of the Division's on-going efforts to reclaim the site. <br /> Now, a year after filing their Third-Party Complaint, after completion of initial <br /> discovery, after provision of the Division's Accounting which specifically lays out the <br /> reclamation plan, after months of discussions, and after the bidding and undertaking of <br /> reclamation by the Division for this season, the Third-Party Plaintiffs want to drastically <br /> amend their complaint. <br /> Rather than merely asking for an accounting from the Division so that the Third-Party <br /> Plaintiffs can account to Pitkin County for unpaid property taxes, the proposed amended <br /> complaint asserts several new claims for relief. Asserted in the amended complaint are <br /> generalized claims for a further accounting from the Division; for damages based on a theory <br /> of breach of contract and\or breach of good faith and fair dealing for mostly unspecified <br /> reclamation work already completed and for work to be undertaken in the future; for an <br /> injunction to prevent demolition of certain structures which are not owned by the Third-Party <br /> Plaintiffs but by a limited liability corporation not named as a party to this action; and for a <br /> declaratory judgment concerning liability under a discharge permit issued by the Colorado <br /> 4 <br />