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Home My WebLink About20072128.tiff DISTRICT COURT, BROOMFIELD COUNTY, COLORADO Court address: 17 DesCombes Drive Broomfield, Colorado 80020 Petitioner: Broomfield Urban Renewal Authority v. Respondents: Northlands, LLC, et al. ♦COURT USE ONLY A Case Number: 2006-CV-148 Susan L. Aldridge, #28516 BEATTY &WOZNIAK, P.C. Div.: A 216 Sixteenth Street, Suite 1100 Denver, CO 80202-5115 Phone Number: 303-407-4499 Fax Number: 303-407-4494 saldridge@bwenergylaw.com Attorney for SOCO Wattenberg Corporation and Snyder Oil Corporation(n/k/a Noble Energy, Inc.) DISCLAIMER OF INTEREST AND STIPULATION OF DISMISSAL WITH PREJUDICE Pursuant to C.R.C.P. 41(a)(1), Petitioner Broomfield Urban Renewal Authority and Respondents SOCO Wattenberg Corporation, Snyder Oil Corporation (n/k/a Noble Energy, Inc.) ("Noble entities"), respectfully move this Court to dismiss with prejudice the Noble entities, and in support of, state as follows: 1. The Noble entities have interests in the property subject to this condemnation, including but not limited to certain oil and gas leasehold rights. Specifically, the Noble entities have an oil and gas interest in the following tract of land: a strip of land for the Bull Canal through, upon over and across the Southeast quarter(SE1/4) of Section thirty-four (34), Township one (1)North, Range sixty- c', 2007-2128 eight (68), West; said strip of land being ninety-five (95) feet wide and extending forty-five (45) feet right and fifty(50) feet left of the center line of the said Bull Canal, as actually constructed, and contains twelve and eighty three one hundredths (12.83) acres. Said center line intersects the boundary line between said Section thirty-four(34) and Section three (3), Township one (1) South, Range sixty-eight (68) West, seven hundred thirty one (731) feet West of the Southeast corner of said Section thirty-four(34), which point is Station 214+ 37 of the survey of the said Bull Canal, and which said center line intersects the boundary line between the Southeast quarter(SE1/4) and the Northeast quarter (NE1/4) of Section thirty- Four (34), eighteen hundred ninety (1890) feet West of the East quarter corner of said Section thirty-four (34), which point is Station 264+ 35 of the survey of the said Bull Canal. 2. Therefore, the Noble entities hereby disclaim any right, title or interest in and to any and all of Section 34, Township 1 North, Range 68 West, 6th P.M., Broomfield, Colorado that it has an interest in as described above, and which property is subject to this action, and to the proceeds of any settlement or judgment herein, and to any royalty interests. Noble reserves any interest it may have in Section 3, Township 1 South, Range 68 West, 6i° P.M., Broomfield, Colorado or any other section that may be described herein or otherwise owned by the Noble entities and not covered by Exhibit A to Plaintiffs' Complaint. 3. Each party has agreed to bear its own respective attorneys' fees, costs, and expenses incurred with regard to this action. Pursuant to C.R.C.P. 105(c), costs shall not be recovered against the Noble entities. 4. This Agreement represents the full and complete understanding of the parties, and cannot be changed or modified unless in writing duly signed by both parties. 5. Accordingly, the parties hereby submit this Stipulation of Dismissal with Prejudice. Dated this 17`" day of July, 2007. MAY AND ASSOCIATES,P.C. /s/Mark E. May Mark E. May, #12049 ATTORNEY FOR PETITIONER BEATTY&WOZNIAK,P.C. /s/ Susan L. Adridge Susan L. Aldridge, #28516 ATTORNEY FOR DEFENDANTS SOCO WATTENBERG CORP. AND SNYDER OIL CORP. (N/K/A NOBLE ENERGY, INC.) Original signature on file in the offices of Beatty & Wozniak, P.C. CERTIFICATE OF SERVICE The undersigned hereby certifies that on this 17`h day of July, 2007, a true and correct copy of the foregoing DISCLAIMER OF INTEREST AND STIPULATION OF DISMISSAL WITHOUT PREJUDICE was e-served via LexisNexis File & Serve or U.S. Mail, properly directed as follows: Richard F. Rodriguez, Esq. The Farmer's Reservoir and Irrigation Co. Holme Roberts & Owen, LLP a Colorado Corporation 1700 Lincoln Street, Suite 4100 Albert F. Sack, Reg Agt Denver, CO 80203-4541 80 South 27th Avenue Attorney for Respondent Brighton, CO 80601 Kerr-McGee Rocky Mountain Corporation John W. Suthers, Attorney General Mikaela V. Rivera, Esq. Gregg E. Carson, Assistant Attorney General Otten, Johnson, Robinson, Neff&Ragonetti, 1525 Sherman Street, 5th Floor P.C. Denver, CO 80203 950 17th Street, Suite 1600 Attorney for CDOT Denver, CO 80202 Attorney for LaSalle Bank, N.A. Edward J. Blieszner, Esq. Gail D. Kats, individually and as Paige L. Mackey, Esq. Trustee of The Margaret Kats Revocable Trust Icenogle, Norton, Smith & Blieszner, P.C. 10185 East Lake Drive 821 17th Street, Suite 600 Englewood, CO 80111 Denver, CO 80202 Attorney for EnCana Oil & Gas (USA) Inc. and EnCana Energy Resources, Inc. Terril Koops, Sam Kats and Betty J Kats, Trustees Personal Representative of the of The Betty J. Kats Living Trust and The Sam Estate of Aloise E. Ramaker Kats Living Trust Aka Aloise Ramanker, Deceased 591 Park Street 2235 S. Cherry Street Route 2, Box 13 Denver, CO 80222-5004 Phillipsburg, KS 67661 Children's Community Foundation, Weld County, Colorado Trustee of The Sam Kats and Betty Kats a quasi municipal corporation Charitable Remainder Unitrust c/o Board of County Commissioners 591 Park Street Weld County Centennial Center Route 2, Box 13 915 10`h Street Phillipsburg, KS 67661 Greeley, CO 80631 Denver Ten LLC Exco Resources, Inc. A Nevada limited liability company CT Corporation, Registered Agent Kevin E. Burke, Resident Agent 1675 Broadway 3365 Wynn Road, Suite A Denver, CO 80202 Las Vegas, NV 89102 Julie S. Harrington Century Stimulation and Engineering LLC 2236 S. Jackson Nelson E. Williams, Member/Manager Denver, CO 80210 2583 S. Balsam Street Lakewood, CO Chris Ann Borla Colorado National Bank—Northeast 546 Sherman nka US Bank National Association Potter, NE 69156 The Corporation Company, Registered Agent 1675 Broadway Denver, CO 80202 Wells Fargo Bank, N.A. Endowment Energy partners, LP Corporation Service Company, Reg Agt Corporation Service Company, Registered 1560 Broadway Agent Denver, CO 80202 2711 Centerville Road, Suite 400 Wilmington, DE 19808 Mineral Resources, Inc. FirsTier Bank a Colorado Corporation Nka Compass Bank Charles Bewley, Registered Agent Timothy D. Wiens, Registered Agent 370 17th Street, Suite 4800 11210 Huron Street Denver, CO 80202 Northglenn, CO 80234 The Elizabeth N. Doores Trust Margret L. Niven and Grant V. Niven, 1373 North Cherry Street Co-Trustees of the Margret L. Niven Galesburg, IL 61401 Revocable Trust and the Grant V. Niven Revocable Trust 215 S.W. Yorkshire Road Topeka, KS 66606 William E. Johnson, Trustee of the Elda Mae Elda Mae Johnson, Individually and as Johnson Revocable Living Trust Personal Representative of the Estate of 2805 Brockett Avenue George E. Johnson Yakima, WA 98902 2805 Brockett Avenue Yakima, WA 98902 JP Morgan Chase Bank,N.A. CT Corporation System, Registered Agent 350 N. St. Paul St. Dallas, TX 75201 Original signature on file in the offices of Beatty & Wozniak, P.C. /s/Gabrielle H. Graham 64538v2 Hello