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HomeMy WebLinkAbout20020766.tiff "`nP l C I Nf) PETITION We, the undersigned residents of Weld County, hereby petition Weld County to deny the permit for a landscape materials facility located 'A mile east of County Road 35 on County Road 12, as requested by Bob Oman of Select Materials. Select Materials is currently permitted to haul sand out of the location but not to bring anything in. They are requesting a change of use that would allow them to make the current location their headquarters for a major landscape materials facility. This proposed use could affect the safety and welfare of the businesses and residences in the area by substantially increasing the heavy truck traffic on the local roads and result in accelerated deterioration of roads and the possibility of increased accidents. Additional impacts will include an increase in air pollution with dust and flies, and noise pollution. There are already several industrial businesses located within the area. B.O.S.S. Compost is a composting facility located on the southwest corner of County Roads 35 and 12. The northwest corner holds a semi-truck maintenance facility, Stealth Trucking. Just north of the intersection is C&J Towing, complete with an outdoor storage facility. All of these businesses create heavy truck traffic on County Road 35. The intersection of County Road 35 with Highway 52 is already challenged with the amount of traffic from existing businesses and homes. It will be further challenged as the 52 homes in Buffalo Ridge Estates are completed and occupied. Improvements are desired at this intersection to provide the necessary safety and another business with heavy truck traffic as proposed would create additional problems. We wish to preserve the current Agricultural zoning that the County has approved for this area and maintain the peacefulness that this zoning offers. The operation that Select Materials is proposing would have adverse impacts to the safety and welfare of our community as well as depreciate the value of our homes. Therefore, we petition that the County deny the permit for Select Materials. This petition will be sent to: Weld County Commissioners 915 Tenth St. P.O. Box 758 Greeley, CO 80632 O`pti' Weld County Planning Commission (\e�� 1555 N. 17t Ave. Greeley, CO 80631 \aG ,)( . y- nay EXHIBIT 2002-0766 _ .er 1717! (-t/men Cr. Ff I v,iJc W 90621 I ,, e7 / /7/ /1)1i/0 d>,e, at/I0 do L . lute LAA-44 OL'"\-ki 'PO ,c, x\33-3 (---;..\Loy-, 4t \\ CD b li LA 'f 4a-t felDI , � U r r-. PETITION We, the undersigned residents of Weld County, hereby petition Weld County to deny the permit for a landscape materials facility located Vsi mile east of County Road 35 on County Road 12, as requested by Bob Oman of Select Materials. Select Materials is currently permitted to haul sand out of the location but not to bring anything in. They are requesting a change of use that would allow them to make the current location their headquarters for a major landscape materials facility. This proposed use could affect the safety and welfare of the businesses and residences in the area by substantially increasing the heavy truck traffic on the local roads and result in accelerated deterioration of roads and the possibility of increased accidents. Additional impacts will include an increase in air pollution with dust and flies, and noise pollution. There are already several industrial businesses located within the area. B.O.S.S. Compost is a composting facility located on the southwest corner of County Roads 35 and 12. The northwest corner holds a semi-truck maintenance facility, Stealth Trucking. Just north of the intersection is C&J Towing, complete with an outdoor storage facility. All of these businesses create heavy truck traffic on County Road 35. The intersection of County Road 35 with Highway 52 is already challenged with the amount of traffic from existing businesses and homes. It will be further challenged as the 52 homes in Buffalo Ridge Estates are completed and occupied. Improvements are desired at this intersection to provide the necessary safety and another business with heavy truck traffic as proposed would create additional problems. We wish to preserve the current Agricultural zoning that the County has approved for this area and maintain the peacefulness that this zoning offers. The operation that Select Materials is proposing would have adverse impacts to the safety and welfare of our community as well as depreciate the value of our homes. Therefore, we petition that the County deny the permit for Select Materials. This petition will be sent to: Weld County Commissioners 915 Tenth St. P.O. Box 758 Greeley, CO 80632 Weld County Planning Commission 1555 N. 17th Ave. Greeley, CO 80631 /� �/ / 3R3 a's7/gZ>3 Y4'/ /��� CC)(Ae�� 7/ a57 73 jO3isz Zap 42r(t13154 (724o ,�1.t ,f, (J Sob)" r 111203 cock R. Lv CQ 1 1 env. .- fl " cam 177-Th EAGLE_ 5A F i s LVQTc' bcLZ, 1 :147 /)7 deiiz /, /7&± ie�4 ' f��' / 15 '-1345 Elitpbeeh &L , gl p7 - ‘ ' i<-u< de Si., ,tiro U 111 1 /(�`f t?/ co jaco3 /l Z'�J/py' , 19-0% '-13�I5 Et, acLbc-(i-1 Sr t3r%gn6->e3, s're cv <6 /. [l / ,v / 75W ati43 in? i?.4To.1 ��c -PLA 4 6itacirisA rl -0Co fo(0c3 I ay) ThA 936 fu ///4774 Sr betl.kroA 'aUos 1AMc5 WIi4y 17C.3C A+ lrIE 5 /3:_;An rtAic �v /t - -%- L-ek.it. /74-4 tk , .11 & L d ld p ei/ 1 / ,/ wan c, .cg1 � Buz r;4d 117 AI /n D.S . /7,2 6 ' ;7'/6 R./,Z 7:777Z-;,e. b O!0 2 rN 77o5 >/ / 72_6z (dote /a ( / ZrzeryCO cicnEi Z-/ r - - n. .-. i-, 02,-)- S 7 a3 ft'n-"-_'- `11--- --a.-ti- `f($D %ten-- 5r. cftci.5- SIts.ftst) 3øi1 -0µ17 r1tita._ tnci.. 172.7o EA-, - et. 7t y, d�Jb 1.i ���, >% 49.--- /7/7/ Weld L'i/G ,9Z1t Psi-6353 V/ / FLto,2 d2 � //�� 3o3-8s7- iurec� / u7G%- . o / /.3—D �uv erL U/9/ %) C �� a /7i SO ` .-6 iiii afterd►. m r9/ r PETITION We, the undersigned residents of Weld County, hereby petition Weld County to deny the permit for a landscape materials facility located 1/4 mile east of County Road 35 on County Road 12, as requested by Bob Oman of Select Materials. Select Materials is currently permitted to haul sand out of the location but not to bring anything in. They are requesting a change of use that would allow them to make the current location their headquarters for a major landscape materials facility. This proposed use could affect the safety and welfare of the businesses and residences in the area by substantially increasing the heavy truck traffic on the local roads and result in accelerated deterioration of roads and the possibility of increased accidents. Additional impacts will include an increase in air pollution with dust and flies, and noise pollution. There are already several industrial businesses located within the area. B.O.S.S. Compost is a composting facility located on the southwest corner of County Roads 35 and 12. The northwest corner holds a semi-truck maintenance facility, Stealth Trucking. Just north of the intersection is C&J Towing, complete with an outdoor storage facility. All of these businesses create heavy truck traffic on County Road 35. The intersection of County Road 35 with Highway 52 is already challenged with the amount of traffic from existing businesses and homes. It will be further challenged as the 52 homes in Buffalo Ridge Estates are completed and occupied. Improvements are desired at this intersection to provide the necessary safety and another business with heavy truck traffic as proposed would create additional problems. We wish to preserve the current Agricultural zoning that the County has approved for this area and maintain the peacefulness that this zoning offers. The operation that Select Materials is proposing would have adverse impacts to the safety and welfare of our community as well as depreciate the value of our homes. Therefore, we petition that the County deny the permit for Select Materials. This petition will be sent to: Weld County Commissioners 915 Tenth St. P.O. Box 758 Greeley, CO 80632 Weld County Planning Commission 1555 N. 17th Ave. Greeley, CO 80631 • i\\c bc-e :(i`n7 %273 Falcon Or 3«3 - 857-0 z / CAJH rip 303- UPS-0(0 /(;) h ie lti , 5 62 -2;-7-94"?' C'4 L 1De 6/L/il/6 Y 7 3 FAtc.c .0 De. } 0i2. 1 13. 3 2 �,ptr9s A2 sei; ,-0,57-1225) 441;c l&LL /-�', L I,S' I/1V0 gtl et,i (?3 9t t-ko6 Feb 18 02 12: 08p TODP.-NHODGES DESIGN LLC 158188059 p. 1 DISTRICT COURT,WELD COUNTY,COLORADO Court Address: 901 Ninth Avenue Greeley,CO 80631 . P.O. Box 2038 Greeley, CO 80632 Plaintiff(s): Timothy Norman Trostel Mary Teresa Trostel • Defendant(s): Arthur H. Suppi David L. Suppi Teddy R.Mcirvin Darlene C. Mclrvin Martin J.Freedman Panhandle Eastern Pipe Line Company United Power, Inc.,1/k/a Union Rural Electric Association, Inc. Robert D.Oman The Board of County Commission- ers of the County of Weld,State of Colorado All unknown persons who claim any interest in the subject matter of this action COURT USE ONLY Judge: Robert A. Behrman Case No. 2000 CV 47 Senior Judge Judge's Address: Post Office Box 427 Div.: 1 Ctrm. Greeley, CO 80632-0427 Phone Number: (970) 352-3061 FAX Number: None E-mail: .. JudgeRAB@aol.com Atty. Reg.# 3613 MEMORANDUM OF DECISION AND ORDER FOR JUDGMENT This is an action to quiet title to certain property in Weld county, Colorado. That property is described as follows: UXHISIT on, Feb 18 02 12: 08p T0Dy-9410DGES DESIGN LLC 1561$2,88059 p. 2 THAT PART OFTHE SOUTHEAST ONE-QUARTER SOUTHWEST ONE- QUARTER SECTION 1,TOWNSHIP 1 NORTH,RANGE 66 WEST OFTHE 6TH PRINCIPAL MERIDIAN MORE PARTICULARLY DESCRIBED AS: BEGINNING AT THE SOUTHWEST CORNER SAID SOUTHEAST ONE- QUARTER SOUTHWEST ONE-QUARTER;THENCE NOO°2525"E ALONG THE WEST LINE SOUTHEAST ONE-QUARTER SOUTHWEST ONE-QUARTER SECTION 1 A DISTANCE OF 33.86 FEET TO A POINT ON AN EXISTING FENCELINE;THENCE EASTERLY ALONG SAID EXISTING FENCELINE THE FOLLOWING(10)COURSES AND DISTANCES:N89°38'53"E, 178.38 FEET; 389°52'53"E, 203.14 FEET; S89°53'38"E, 187.90 FEET; S89°32'18"E, 179.09 FEET; N89°57'42"E, 144.91 FEET; S89°55'21"E, 80.73 FEET; S89°50'48"E, 105.81 FEET; S89°35'56"E, 107.43 FEET; N68°17'23°E, 125.51 FEET; N68°17'23"E, 6.92 FEET TO A POINT ON THE EAST LINE SOUTHEAST ONE- QUARTER SOUTHWEST ONE-QUARTER SAID SECTION 1;THENCE S00°33'43'W ALONG THE EAST LINE SOUTHEAST ONE-QUARTER SOUTHWEST ONE- QUARTER SAID SECTION 1 A DISTANCE OF 82.33 FEET TO THE SOUTHEAST CORNER OF THE SOUTHEAST ONE-QUARTER SOUTHWEST ONE-QUARTER SAID SECTION 1;THENCE N89°55'41"W ALONG THE SOUTH LINE SAID SOUTHEAST ONE-QUARTER SOUTHWEST ONE-QUARTER SAID SECTION 1 A DISTANCE OF 1309.84 FEET TO THE POINT OF BEGINNING. Trial was held on November 5, 2001. The trial was limited to the claims of the plaintiffs as they relate to the dispute between the plaintiffs and defendant Robert D. Oman. There is little disagreement as to the underlying facts of the case, although the legal effects of those facts is hotly disputed. Since December 7, 1977, the plaintiffs have been the record owners of a parcel of land located in the Northeast Quarter of the Northwest Quarter of Section 12, Township 1 North , Range 66 West of the 6th Principal Meridian in Weld County, Colorado. Defendant Robert D. Oman is the current record owner of the Southeast Quarter of the Southwest Quarter of Section 1, Township 1 North , Range 66 West of the 6th Principal Meridian in the same county. The plaintiffs' property is directly south of defendant Oman's property. Defendant Arthur H. Suppi is a former owner of the Oman property and is the immediate predecessor in title to Robert D. Oman. Suppi's interest in the property, in one form or another, appears to date from October 13, 1976. He now is the beneficiary of a deed of trust covering the Oman property. The section line between Sections 1 and 12 of Section 1 North, Range 66 West separates the properties of the plaintiffs and defendant Oman. By resolution of the �-. 2 ' Feb 18 02 12: 08p T0DP�H0DGES DESIGN LLC 1561$ 88059 p. 3 • • Board of County Commissioners of Weld County dated October 12, 1889, that section line and other section and township lines in the county, were "declared to be the center of public highways or County roads," and those roads were "declared to be roads 60 feet wide, being 30 feet on each side of said section and township lines." The sixty-foot strip between the properties of the parties has been designated County Road 12; however, it was never opened or improved as a road. The county has never taken action to formally abandon the 60 foot strip as a road. On January 7. 2000, the defendant Board of County Commissioners granted to defendant Oman a "Nonexclusive License Agreement for the Upgrade and Maintenance of Weld County Right-of-Way" permitting Oman to upgrade and maintain a portion of the county right- of-way between the parties' properties. A part of the area between the parties' properties, toward its easterly end, is occupied by the canal and canal road of the Farmers Reservoir and Irrigation Company ("FRICO") which is not a party to this action. The canal and canal road cut across the south-east corner of defendant Oman's property. At some time more than twenty years ago, a predecessor of Oman constructed a fence which is slightly more than 30 feet north of the true section line between sections 1 and 12. The fence runs roughly parallel to the true section line about 33 feet north of the true section line until near the eastern end of the boundary at which point it turns in a north easterly direction along edge of the FRICO canal and canal road. The exact location of the fence is described In the legal description set forth above. By their complaint plaintiffs seek to quiet title to the entire property between the true section line between the true section line between Sections 1 and 12 and the fence. This area includes the north half of the county road. It also includes portions of the right-of-way for the FRICO ditch, although FRICO is not a party to this action. In the legal description admitted in evidence the plaintiffs acknowledge that the property is subject to road and ditch rights-of-way. The area involved totals 1.10 acres more or less. For more than twenty years it has been the practice of the plaintiffs to use the area up to the fence as if it were their own property. Items of farm machinery and other personal property were stored there, crops were occasionally planted there and livestock belonging to the plaintiffs grazed there. Defendant Oman and his predecessors in title made no objection to such use by plaintiffs. On one or more occasions Oman offered to pay plaintiffs to remove the items stored in the area south 3 ' Feb 18 02 12: 09p T0DP,,H0DGES DESIGN LLC 156188059 p. 4 • • of the fence. Plaintiffs were well aware of the existence of the county-road right-of-way on the north part of their property, but believed that, because of the presence of the FRICO canal at the east end, the road would never be opened. They believed that they would have perpetual use of the area involved; however, they took no action to seek formal abandonment of the road by the county authorities. Plaintiffs base theft claims on two statutes, C.R.S.§38-44-109, and C.R.S. §38- 41-101. The applicability of these two statutes to the fact situation involved here will be discussed separately; however, first the status of the county road must be considered. STATUS OF COUNTY ROAD 12. As pointed out above, County Road 12 has not been opened or improved as a road. The status of such a road has been considered by our Supreme Court in Uhl v. McEndaffer, 123 Cola 69, 225 P.2d 839 (1950). That case concerned the identical dedication which is Involved here. The case arose on appeal from a judgment of the former County Court of this county. Our Supreme Court said: Counsel for plaintiff, defendant in error, insists that the primary question here is whether or not the resolution of the board of county commissioners ordering certain section lines to be the center of public highways is sufficient to create a public highway or road without either a user or the construction of such road. The validity of the dedication is admitted. In fact this resolution may be deemed to be stronger and more far-reaching than a bare dedication, as the term is ordinarily accepted. It provides that the section line is declared to be the center of public highways or county roads, which roads are declared to be roads sixty feet wide, being thirty feet on each side of said section and township line and, in the words of the statute, delegating such authority to the board of county commissioners, it is said, "The road so laid out shall be a public highway." '35 C.S.A., c. 143, § 44. (Italics ours.) In view of this declaration, it must be said that the lands here involved, being thirty feet on each side of the section line, compose a public highway and remains as such until vacated or abandoned by some appropriate action of the board of county commissioners. The purpose of the declaration was to provide the right of lawful access to adjacent property. The very purpose of the act would be thwarted if it r- 4 ' Feb 18 02 12: 09p T0Dy- k10DGES DESIGN LLC issisapeoss p. 5 • was held that unless some physical action on the part of the county authorities in developing or improving the work was performed, in time, nonuse could be said to be a vacation or abandonment. The lines of the roadway are prescribed and await the use thereof by one or more,and that, until such time as statutory provisions for vacating the dedication have been complied with. Our Supreme Court further stated: The owners or purchasers of land lying within the district described in the resolution of the board of county commissioners here in evidence, knowing that the section lines, as such, are burdened with a dedication of a highway thirty feet on each side, then the use thereof by such owners or purchasers of the land on either side of the section line is subject to the existing right of use by those within the area entitled to ingress and egress to an open highway, and if there is no such use required, the owners, having knowledge of such burden, should take the necessary statutory steps to have the highway vacated if they purpose to claim the land as their own. This doctrine has recently been reaffirmed by our Court of Appeals in a somewhat parallel situation. The court said: Absent effective vacation, the roadways remain dedicated to the public. See Uhl v. McEndaffer, 123 Cob. 69, 225 P.2d 839 (1950). Martini v. Smith, 18 P.3d 776 (Cob. App. 2000). This court is somewhat unclear as to the precise position of the plaintiffs regarding County Road 12. They have stipulated that the decision in this case will not affect any interest of the county and the legal description in evidence acknowledges county rights-of-way. Nevertheless, the testimony of plaintiff Timothy Norman Trostel seemed to indicate a view that plaintiffs had acquired permanent exclusive rights over the county road. The court finds that there is no evidence that plaintiffs have taken "the necessary statutory steps to have the highway vacated," and consequently County Road 12 at all relevant times has been, and continues to be, a valid public highway. '—' 5 ' Feb 18 02 12: 09p T0DjY�H0DGES DESIGN LLC 156188059 p. 6 PLAINTIFFS' CLAIM UNDER C.R.S.§38-44-109. C.R.S.§38-44-109 provides as follows: 38-44-109. Corners and boundaries established. The corners and boundaries finally established by the court in such proceedings, or an appeal therefrom, shall be binding upon all the parties, their heirs and assigns, as the corners and boundaries which have been lost, destroyed, or in dispute: but it it is found that the boundaries and corners alleged.to have been recognized and acquiesced in for twenty years have been so recognized and acquiesced in, such recognized boundaries and corners shall be permanently established. In discussing the application of this statute our Supreme Court has said: As a general proposition of law, it is true that there must be mutuality in the fixing of a boundary in order for acquiescence to be found. Hartley v. Roybal, 160 Cob. 80, 414 P.2d 114 (1966). Plaintiffs contend that the parties have recognized the fence line as the boundary between their respective properties for more than the statutory period. The preponderance of the evidence does not support that view. As pointed out above, the exact position of plaintiffs as to County Road 12 is unclear. It is evident that the plaintiffs have made use of the land as their own at least until the point where the fence veers to the northeast following the FRICO ditch and ditch road. Use of the property in the latter area by plaintiffs is not shown. It is unclear to the court if the plaintiffs believed (1) that the fence line marked the section line between sections 1 and 12, or (2) that the fence marked the north boundary of County Road 12, and that because it was impractical to open that road they would have permanent use of the area up to the fence. The court thinks that the second alternative is the more likely. The court finds that defendants Arthur H. Suppi and Robert D. Oman believed that the fence separated their property from County Road 12 and the FRICO ditch and ditch road. They did not recognize it as the boundary between their property and the property of plaintiffs. The builder of the fence apparently recognized that there was no 6 ' Feb 18 02 12: 09p T0Dy-.fI0DGES DESIGN LLC 15618059 p. 7 • • right to place a fence so as be an obstruction to the county road. Uhl v. McEndaffer, supra. The court bases this finding on the testimony of defendants Arthur H. Suppi and Robert D. Oman and believes it is supported by the apparently obvious jog in the fence line to follow the boundary of the FRICO instillations. The fence is a barrier fence rather than a boundary fence. The court's finding that defendants Arthur H. Suppi and Robert D. Oman did not consider the fence to be the boundary between their property and that of the plaintiffs leads to the conclusion that the requisite acquiescence is absent. Accordingly plaintiffs' claims under C.R.S.§3B-44-109 must be denied. PLAINTIFFS' CLAIM UNDER C.R.S.§38-41-101. C.R.S.§38.41-101 provides as follows: 38-41-101. Limitation of eighteen years ( 1) No person shall commence or maintain an action for the recovery of the title or possession or to enforce or establish any right or interest of or to real property or make an entry thereon unless commenced within eighteen years after the right to bring such action or make such entry has first accrued or within eighteen years after he or those from, by, or under whom he claims have been seized or possessed of the premises. Eighteen years adverse possession of any land shall be conclusive evidence of absolute ownership. (2) The limitation provided for in subsection ( 1) of this section shall not apply against the state, county, city and county, city, irrigation district, public, municipal, or quasi-municipal corporation, or any department or agency thereof. No possession by any person, firm, or corporation, no matter how long continued, of any land, water, water right, easement, or other property whatsoever dedicated to or owned by the state of Colorado, or any county, city and county, city, irrigation district, public, municipal, or quasi-municipal corporation, or any department or agency thereof shall ever ripen into any title, interest, or right against the state of Colorado, or such county, city and county, city, public, municipal, or quasi-municipal corporation, irrigation district, or any department or agency thereof. Our Court of Appeals has defined the elements which must be proven to �^ 7 Feb 18 02 12: 10p T0Dp1H0DGES DESIGN LLC 1561$-8805S p. 8 • /1 acquire title under this statute. The Court of Appeals said: To acquire land by adverse possession, one must prove possession of the disputed parcel for the statutory period of 18 years and that this possession was hostile, adverse, actual, under a claim of right, exclusive, and uninterrupted. Board of County Commissioners of Cheyenne County, Colorado, v. Ritchey, 888 P.2d 298 (Colo. App.1994 ) Likewise our Supreme Court has said One claiming title by adverse possession must prove that his possession of the disputed parcel was actual, adverse, hostile, under claim of right, exclusive and uninterrupted for the statutory period. Smith v. Hayden, 772 P.2d 47 (Colo. 1989) Although the evidence in the case may be sufficient to prove that plaintiffs' possession was hostile, adverse, and uninterrupted, the principal question which arises is, "Was it actual and exclusive?" This aspect of the case is governed by two decisions of our appellate courts, Webber v, Wannemaker, 39 Colo. 425, 89 P. 780 (1907) and Palmer Ranch, Ltd. v. Suwansawasdi, 920 P.2d 870 (Cob. App.1996). In the Webber case a claim of title by adverse possession was denied by our Supreme Court, which used the following language: The evidence shows that the twenty-five acres in controversy were fenced, in the first instance, in common with fifty-five acres of other land belonging to persons other than the plaintiff or her grantors; that thereafter the fence was taken away. This is not evidence in support of adverse possession. It is not actual and exclusive possession, but a possession in conjunction with other land owners and it falls far short of that kind of adverse possession which deprives the true owner of his title. The Palmer Ranch, Ltd. case the Court of Appeals recognized the controlling authority of the Webber case, but distinguished it on the following grounds: ,r-. 8 • Feb 18 02 12: 1Op TOD,a,HODGES DESIGN LLC 15618'88059 p. 5 r In contrast, here, it is uncontradicted that Palmer Ranch claimed and exercised actual and exclusive possession for approximately thirty-five years to all land within the perimeter fence that it had maintained. Because one cannot claim adverse possession to public land, Palmer Ranch has not and cannot assert a fee simple interest in the BLM land. Nevertheless, the undisputed testimony was that, by virtue of its grazing lease with BLM, Palmer Ranch has enjoyed exclusive possession of the BLM property within the perimeter fence since 1956, interrupted only by sporadic entries by hunters. [Emphasis supplied.] In the present case the plaintiff cannot assert the claim to exclusive possession relied on in the Palmer Ranch, Ltd. case. It has no grant of exclusivity from the county regarding County Road 12, nor, as far as the evidence shows, has it any such grant from FRICO. Accordingly this court concludes that this case is governed by the Webber case and that plaintiffs' claim for title by adverse possession cannot be sustained. PLAINTIFFS' CLAIMS SHOULD BE CONSIDERED AS A WHOLE. Plaintiffs appear to assert that regardless of the validity of their claims to County Road 12 and their failure to assert claims against FRICO, their claims against defendants for a strip about three feet wide just north of the true boundary of County Road 12 should be separately recognized. This court disagrees. The evidence produced by plaintiffs in support of their claims was based on their use and occupancy of the entire area set forth in the description above. It did not detail separate and specific use of the three-foot strip north of County Road 12, and indeed from the pictures submitted in evidence it is not evident that plaintiffs' use extended right up to the fence. The only purpose for recognition of the three-foot strip as a separate entity would be to deprive defendant Robert D. Oman and his successors of access to County Road 12. This may be plaintiffs' purpose.1 1 There was some indication at trial of demands by plaintiffs for substantial sums for granting such access to defendant Oman. ^ 9 Feb 18 02 12: 11p T0D➢-.40DGES DESIGN LLC 158188059 p. 10 Origin of this dispute appears to be a possible slight mistake as to the location of the north boundary of County Road 12. To paraphrase Uhf v. McEndaffer, supra, if plaintiffs' claim were granted under such ambiguous circumstances, the very purpose of the act which authorized creation of County Road 12 would be thwarted. ORDER For the reasons set forth above, it is ORDERED, ADJUDGED and DECREED by the court as follows: 1. Judgment shall enter that plaintiffs Timothy Norman Trostel and Mary Teresa Trostel have no right, title or interest in and to the following described property in Weld County, Colorado, to-wit: THAT PART OF THE SOUTHEAST ONE-QUARTER SOUTHWEST ONE- QUARTER SECTION 1,TOWNSHIP 1 NORTH,RANGE 66 WEST OFTHE 6TH PRINCIPAL MERIDIAN MORE PARTICULARLY DESCRIBED AS: BEGINNING AT THE SOUTHWEST CORNER SAID SOUTHEAST ONE- QUARTER SOUTHWEST ONE-QUARTER;THENCE N00°25'25"E ALONG THE WEST LINE SOUTHEAST ONE-QUARTER SOUTHWEST ONE-QUARTER SECTION 1 A DISTANCE OF 33.86 FEET TO A POINT ON AN EXISTING FENCELINE;THENCE EASTERLY ALONG SAID EXISTING FENCELINE THE FOLLOWING(10)COURSES AND DISTANCES:N89°38'53"E; 178.38 FEET; S89°52'53"E, 203.14 FEET; S69°53'38"E, 187.90 FEET; S89°32'18"E, 179.09 FEET; N89°57'42"E, 144.91 FEET; S89°55'21"E, 80.73 FEET; 589°50'48"E, 105.81 FEET; S89°35'56"E, 107.43 FEET; N68°17'23"E, 125.51 FEET; N68°17'23"E,6.92 FEET TO A POINT ON THE EAST LINE SOUTHEAST ONE- QUARTER SOUTHWEST ONE-QUARTER SAID SECTION 1;THENCE S0o°33'43'W ALONG THE EAST LINE SOUTHEAST ONE-QUARTER SOUTHWEST ONE- QUARTER SAID SECTION 1 A DISTANCE OF 82.33 FEET TO THE SOUTHEAST CORNER OF THE SOUTHEAST ONE-QUARTER SOUTHWEST ONE-QUARTER SAID SECTION 1;THENCE N89°55'41'W ALONG THE SOUTH LINE SAID SOUTHEAST ONE-QUARTER SOUTHWEST ONE-QUARTER SAID SECTION 1 A DISTANCE OF 1309.84 FEET TO THE POINT OF BEGINNING. 2. Nothing herein shall be deemed to deprive plaintiffs Timothy Norman Trostel and Mary Teresa Trostel of any right they may have as members of the public and as adjoining landowners to make use of County Road 12. 3. Defendants Arthur H. Suppi and Robert D. Oman shall have judgment ea. 10 Feb 18 02 12: llp TOD�HODGES DESIGN LLC 15618'88059 p. 11 against plaintiffs Timothy Norman Trostel and Mary Teresa Trostel for their costs. 4. All parties are granted thirty days from the date of this order for the filing of post-trial motions and bills of costs. 5. The originals of any such motions or bills of costs shall be filed in the usual manner with the clerk of this court and a copy of each shall be mailed to the undersigned judge at the judge's address as shown in the caption. The originals filed with the clerk shall be endorsed with a certificate showing such mailing. Dated December 17, 2001 NT^n.• BY THECOPTh. Robert A.'Behrman Senior Judge On December 17, 2001, copies of the foregoing Memorandum of Decision and Order were mailed to: Kimberly A. Allegretti, Esq. Wood, Ris& Hames, P.C. 1775 Sherman Street, Suite 1600 Denver, CO 80203 Joseph Adams Cope, Esq. Frascona, Joiner, Goodman and Greenstein, P.C. 4750 Table Mesa Drive Boulder, CO 80305-5575 Don J. Hoff, Esq. 1025 9th Avenue, Suite 309 Greeley, CO 80631 Bruce T. Barker, Esq. Weld County Attorney 915 Tenth Street P.O. Box 1948 Greeley, CO 80632 r 11 access to WCR 12 -1''',2'::•-,',/,,, Ali YYy x '« 6 s5. t. y a ,a C ' x i$ya+;' -1: 'ia ';' j2a f� 1st a r « d 14 i it u < i r'. wig ? dw! z,a .-t 3 ,, ki i ' t ' ('; Mw� a 'h+ ' r%.,.. 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' ^ .,'""P� 1 , vm.;>jk,':141;:12 aY> `�°t� �".*�x'+rr`x.Via..7 SW/C of Site looking East -.- Mkt, ' _ r taiDit fir► <.,�.�.. _ SW/C of Site looking Northeast ,fig✓'%NE..1• *ter ia pa. uto-OwnerS Papa 1 INSURANCE COMPANY 55040 (11/87). 6101 ANACAPRI BLVD. , LANSING, MI 48917-3999 Issued 02-15-2001 TAILORED PROTECTION POLICY DECLARATIONS r AGENCY WATERFIELD INSURANCE AGENCY 32-0008-00 UNIT IN Renewal Effective 04-28-2001 INSURED BOB OMAN 86 POLICY NUMBER 004632-y5302078-01 DBA SELECT MATERIALS ADDRESS PO BOX 280 • Company POLICY TERM FORT Bill 12:01 a.m. 12:01 a.m. LUPTON, CO 80621-0280 04-28-2001to 04-28-2002 In consideration of payment of the premium shown below, attachments to your policy. If' , this policy is repeal, consult attach this Declarations and attach You have any questions, pleas consult with your agent. COMMERCIAL GENERAL LIABILITY COVERAGE LIMITS OF INSURANCE General Aggregate Limit (Other Than Products-Completed Operations) $2,000,000 Personal Products-Completions ed Limit 2,000,000 Each Occurrence Limit Fire Damage Limit 100,000 Any One Fire 1,000,000 Medical Expense Limit 1,000,000 10,000 Any One Person "General Aggregate Limit" shown above, is reinstated once per policy period at no additional charge, in accordance with form 55050. AUDIT TYPE: Annual Audit FORMS THAT APPLY TO LIABILITY: 55118 (08-91) 55146 (07-96) 55091 (01-89) IL0021 (11-85) 55029 (07-87) CG0001 (11-88) IL0017 (11-85) 55050 (07-87) 55064 (07-87) CL175 (02-86) 55137 (06-92) CG2147 (09-89) 59319 (04-99) /-' 55183 (11-95) 55202 (05-00) LOCATION OF PREMISES YOU OWN, RENT OR OCCUPY LOC 001 BLDG 001 111610 Weld County Rd 14 1/2 Fort Lupton, CO 80650 TERRITORY: 002 COUNTY: Weld Classification Premium Subline Basis Rates CODE 00501 Premium Commercial General Liability Prem/Op Prem Plus Endorsement Included Pram/Op Inc Inc At 7G Of The Premises Inc Operation Premium CODE 12683 Gross Fertilizer Dealers And Distributors Prem/Op1,3 Each 1000 00,000 Prod/Comp Op 1,300,000 1.327 $1,725.00 CODE 49950 Additional Interests Lessor Of Leased Equipment . /Park Western Leasing Prem/Op 10,000 .433 $4.00 Cit Group/Equipment Pram/Op 10,000 g .433 $4.00 • EXHIBIT iiiiL ' luto-Ouvners Page 2 55040 (11/8 Issued 02-15- INSURANCE COMPANY TAILORED PROTECTION POLICY DECLARAT) 6101 ANACAPRI BLVD. , LANSING, MI 48917-3999 Renewal Effective 04-28-2 AGENCY WATERFIELD INSURANCE AGENCY IN 32-0008-00 UNIT 86 POLICY NUMBER 004632-4530207E INSURED BOB OMAN DBA SELECT MATERIALS ADDRESS PO BOX 280 Company POLICY TERM Bill 12:01 a.m. 12:01 a.m. FORT LUPTON, CO 80621-0280 04-28-2001to 04-28-2002 In consideration of payment of the premium shown below, this policy is renewed. Please attach this Declarations and attachments to your policy. If you have any questions, please consult with your agent. COMMERCIAL GENERAL LIABILITY COVERAGE Assoc Financial Corp Prem/Op 10,000 .433 LOCATION 001 PREMIUM 52,7 LOCATION OF PREMISES YOU OWN, RENT OR OCCUPY LOC 002 BLDG 001 Wheeler Lake Platteville, CO 80621 TERRITORY: 002 COUNTY: Weld Premium Classification Subline Basis Rates PremiL CODE 49451 Acres Each 1 Vacant Land Prem/Op 10 .901 ; Including Products And/Or Completed Operations (For-Profit) LOCATION 002 PREMIUM • LOCATION OF PREMISES YOU OWN, RENT OR OCCUPY LOC 003 BLDG 001 17269 Weld County Rd *12 Fort Lupton, CO 80650 TERRITORY: 001 COUNTY: Weld Premium Classification Subline Basis Rates Premiu CODE 49451 Acres Each 1 Vacant Land Pram/Op 40 .901 S3 Including Products And/Or Completed Operations (For-Profit) LOCATION 003 PREMIUM $: Hello