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Reception No...............LLAL . .il.J.~ ,. ...........................................................:...............fte.c9rder.
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Tms DEED, Made
19 7 4 ' between
this
11th
day of
October
Recorder's Stamp
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Jefferson
and State of
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G.
Paul Talbert and
Winifred S.
Talbert
of the County of
Colorado, of the first part, and
The City of Wheat Rid~e, a rIunicipal
C or')ora ti on, a corporation
organized and existing under and by virtue of the laws of the State of
, of the second part:
WITNESSETH, That the said parties of the first part, for and in consideration of the sum of
- -Tl cr' - d "11 - (&7 (Joa 00) DOLLARS
lrec lr10lIS<ln va ars c;l.J, . --------------------------------- ,
to the said part y of the first part in hand paid by the said party of the second part, the receipt whereof
is hereby confessed and acknowledged, ha ve remised, released, sold, conveyed and QUIT CLAIMED, and by
these presents do remise, release, seIl, convey and QUIT CLAIM unto the said party of the second part, it~
successors and assigns forever, all the right, title, interest, claim and demand which the said part i e s of the
first part ha ve in and to the foIlowing described
situate, lying and being in the County of
C)
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. WlffiAT; \
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DEED .
'17
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Jefferson
and State of Colorado, to wit:
Legal uescription attached
TO HAVE AND TO HOLD the same, together with all and singular the appurtenances and privileges thereunto
belonging or in anywise thereunto appertaining, and all the estate, right, title, interest and claim whatsoever, of the
said part y of the first part, either in law or equity, to the only proper use, benefit and behoof of the said party
of the second part, its successors and assigns forever.
IN WITNESS WHEREOF, The said part ies of the first part ha ve hereunto set theirhand3
and seals the day and year first above written,
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.................................................................................................. [SEAL]
STATE OF COLORADO,
County of Jefferson
} ss,
19
The foregoing
74,by* G.
instrument was acknowledged before me this / / <<
Paul Talbert and Winifred S. Talbert
day of
(t l"'--:t~,'-{ "\..'
My commission expires
(~V(.C I 'f
, 19 7 C . Witness my hand and official seal.
.....2)m~>:::.~0I;.r.:>;.....Jl:..~..\.J2l:......~.{H;.4"'-L..........
Notary Publle,
._~
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. It by natural person or persons here insert name or names: if by person acting in represen tattve or official capacity or as
attorney-in-fact, then insert name of person as executor, attorney-in.fact or other capacity or description: if by officer of cor-
poration... then insert name of such of ricer or officers. as the president or other ofrieers of such corporation. naming It.-Btatutortl
.Aoknow~dgmen.t. 8688icn1. 1927 .. (... r
No. 522. QUIT CLAIM DEED TO CORPORATION.-Bradford Publishing Co.. 1824 Stout Street. Denver, Colorado. -2.70 2t)'~ ,,)bJ
Z6'/2 ~G6
EXIII 13 IT ^
A parcel of land lying in the NW\ of the SW\ of
S<lction :;>2, '1'3S, H69\<I of the 6th P.M., C.l.ty of Wheat
Ridge, Jefferson County, Colorado, more particularly
described as follows; Beginning at the southeast
corner of Lot 13, Talbert Subdivision, a recorded
plat in Jefferson County, Colorado, said point being
on the ea~t 1 ine of the NW~ of the ~jw':i of sa id Sec-
tion 22; thence Soo06.3'W along the east line of the
NW\ of the SW\ of said Section 22 a distance of 56
feet to the TRUE POINT OF BEGINNING, said point being
614.72 feet south of the northeast corner of the NW~
of the SW~ of said section 22; thence soo06.3'W along
the east line of the NW~ of the SW~ of said Section 22
a distance of 77.42 feet to a point on the northerly
line of a parcel of land described in Book 2411 at
Page 924 of the Official Records of Jefferson County,
Colorado; thence N80029.8'W along the northerly line
of the parcel described in said Book 2411 at Page 924
a distance of 445.99 feet to a point 440 feet west of
the east 1 ine of the NWI.t of the SW\i of lli'lid section 22;
thence NO 006.3' E parallel to the cast line of the NW~4
of the SW~ of said Section 22 a distance of 61.54 feet
to the southwest corner of said Talbert Subdivision;
thence S89046.1'E along tile south line of said Talbert
subdivision a distance of 292.50 feet to the Bouthwest
corner of Lot 13, said Talbert Subdivislon; thence
soo06.3'W parallel to the east line of the NW~ of the
SW~ of said Section 22 a dist~nce of 56 feet to a
point 613.38 feet south of the north 1i llC of the NW'4
of the SW\ of said Section 22; thence SB9046.1'E
parallel to the south line of said Talbert Subdivision
a distance of 147.50 feet to the TRUE POINT OF
BEGINNING.
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Li~tric.t Cou~t for J~ff2Tson Count V and a settlenent was r28ched
~3tL~factc~y to all pa~ties and the Court. Said settlement being
3:J follo!.cJs:
(3) Payment of $3,000.00 by the City of Wheat Ridg~
to G. Paul Talbert and Winnifred S. Talbert.
(0) Agreement thet the Talberts ffiay retain a buffering
tract of lend between their house and the proposed Greenbelt Par~.
Said buffering tract to consist of a strip of property abutting the
Talbert Lot Number 13, and baing 147.5 feet in depth and 55 feet in
width.
(c) Agreement that the City of ~he2t Ridge will have
thp. buFfering aree surveyed and uJill furnish the Talberta with a copy
of said survey.
(d) Agreement that the City of Wheat Ridge will r2-
place the fe~cing w~ich the City wrongfully ~emoved along the r~2~
cf the Talbert's Lot r'U::loer 13. Ssid replaced fe;lcing to be c~13in
liilked fencing.
(e) Agre2~ent that the City of Whest Ridge will have
t~le common bcundary e~lsting between the park and buffering strip
fenced with chain linked fencing, and
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Citv of ~h23t R~d~e to P3V th~ 2~p~rt lJitne33
P;::23 1
court CDS':3,
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f~2S l~sIJr~~rl bV R2~pn~d2nt~,
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2nd
WHEf~EAS, Mr. Maurice F. Fox, the 3t~orn2V employed to
r:Jpresent the CitV, [;CSS submitted his bill in the ~GlOLlnt of S1,C-7S.00,
~nd the expert reel estate appreiser employ~d by the City, Mr. Earl R.
Hauqhar, has submitted his bill in the amount of $1,050.00;
~ow, THEFEFD~E, BE IT RESDL~ED that the foregoing described
~;2ttlpm2nt is hereby ratified; th~ d23cribed s~rv2ying ~nd fencirG
bhall be accomplish2d bv the CitV's D2p3rt~2nt of Parks and R2creatio~;
t~lat tre 12g31 fe.=:3 l~ ~he dl-'OUilt Clr ~;.; I,OiS..UD b.? pa::d t8 nr.. f-13'.J::,ice
F. Fox bV the Treasurar from qccount Nn. 415.21; and th3t all othar
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fees and cc t~ shall b~ Gaid bj thp T~2~3ur~r upan billing fro~ th2
P~lrk L'lici-:; ,~;-'L.:i3iT~[J:~ FL!:iCI..
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P,3ul B. P,brar"son, Ph.D.
\"13YOl'
h TTEST:
Elise Brougham, City Clerk
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IN THE DftSftlCT COURT
IN AND FOR THE COUNTY OF JEFFBRSON
AND STATB OJ COLORADO
Civil Ac~a~ No. 41512
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CITY OF WHEAT RIDGB. a Muntejpal
Corporation, of the County :4>1
Jefferson. State of Colorado.
Ped tto.~.
G. PAUL TALBERT, WINNIPRBD lJ.
TALRBRT, PUBLIC TRUSTEB OF
COUNTY OP JBPPBRSON. TiiB 'f
OF THB COUNTY OF JEPPERSON.
OF COLORADO,
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STIPULATION AND
RULE AND ORDER
and
Respond..,t.
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The partie. lUlreto.\'ly and through their
attorneys. stipulate as fOllow.:
1. The above enditl.ct action came on regularly
for trial before this Court ,__ July 30 and 31, 1974. with
Maurice P. Fox, appearing a."torney for Petitioner, and
George Alan Holley. appear!. as Attorney for Respondents,
G. Paul Talbert and Winnifr.. S. Talbert; a jury of six
persons was regularly impanelled andsworn to try the action
and a stipulation was entered into in Open Court on July
31, 1914.
2. That Petition.l'~ll have jud~lIC!tnt condemning
for its un as is set fortn.." fully in the complaint on
file herein, that certain ,.,'Ii of land described as follows:
A parcel of land lyin,p,fpe NWJc of th0 SWl$ of
Section 22, T35. R69W at~, 6th P.M., City of
Wheat Ridge, Jefferson .. y, Colorado, more
particularly described .. ' oHows: Beginning
at the Southeast corner of ~ot 13, Talbert
Subdivision, a l'ecordedp.\..' in Jefferson County,
Colorado, ..td point b.~: on the east line of
the NW~ of the S~ of 51 .; Section 22; thence SOO
06.3' W along the east ~lA. of the NW\ of the SW~
of said Section 22 a di.~I~. of S6 feet to the
true point of b.linninl~, '.U point being 614.12 feet
south of the llortheaat ....1' of the NW\r Of the SWl(
of said Section 22 i th...,.;;'SOO06. >' W along the eut
line of the NWJc of the .. of said Section 22 a
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distance of 77.42 feet to a point on the northerly
line of a parcel of i_described in Book 2411 at Page
924 of the Officia1!1:_rds of Jefferson County.
Colorado; thence NIO tt.3'W along the northerly
line of the parcel ".tbed in Book 2411 at Pal.
924 a distance ot 40~t.. feet to a point 440 feet
wett or the eut li..f the NWJ, of the Slfll of
said Section 22; th~. NOo06.3'E parallel to the
east line of the NW~ .f the SW_ of said Section 22
a distance of 61.54 ,..'t to the Southwest corner
or said Talbert Sub.~jt.ion; thence 889046.ls along
the south line of ..i4 Talbert Subdivision a dis-
tance of 292.50 f.e," tho southwest corner of Lot
13, said Talbert su_.iI..' ',!.Sion; thence SOo06.3W
parallel to the ea., ria. of the NW~ of the SW\ of
said Section 22 a d....ee of S6 feet to a point
613.88 feet south of t'- north line of the N.~ of
of the SW~ of said ",tion 22; thence 889046.1 D
parallel to the south. line of said Talbert Sub-
division a distance of 147.50 feet to the true point
of beginning.
3. That Resp~.nts. G. Paul Talbert and Winnifred
s. Talbert, shall recover from Petitioner. the total sum of
Three Thousand Dollars ($3.000.00) of which Two Thousand Pour
Hundred Dollars ($7..400.00) was withdrawn by Respondents. G.
Paul Talbert and Winn!fll." 'ralbert. under Court Order dated
July :no 1973.
4. That the Ptthioner will have the common
boundary between Petitio..I"s proposed park and Respondent.,
G. Paul Talbert and Winntfred Talbert's abutting property
surveyed at Petitioner's expense and will further furni~h a
copy of said survey to ".pendentl, Talbert.
5. That Petitlofter shall pay unto Respondents,
G. Paul Talbert and Win.tl-'d S. Talbert, Respondents' costs
and disbursement. incur"d 1n thls action. taxed at and
amounting to $648.50.
6. That the Petltioner shall replace the fencing
which Petitioner through i_i agents. wrongfully removed from
the rear of the Respond.at,. Talbert. Lot 13, Talbert Sub-
division. said replaced '.acing to be ehain linked fencing.
7. That Petitu...r shall have the CODmlon boundary
existinl between Petitioo.r's proposed park and Respondent.
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abutting property, fenced with chain linked fencing.
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MAUll tt p. POX:
Attorney for Plaintiff
4315 Wadsworth Boulevard
Wheat Ridge. Colorado 80033
424-444:5
:~~R~~
George Alan HOlley .
Attorneys for Defendants, TallUtc't
4315 Wadsworth Boulevard
Wheat Ridge, Colorado 80033
423-7131
RUt! AND ORDHR
The above entitled cause coming on regularly
for trial before this Court on July 30 and 31. 1974, with
Maurice F. Fox, appearing as attorney for Petitioner, and
George Alan Holley, .p,.aring as Attor.ey for Respondents,
G. Paul Talbert and lUuifred S. Talbert; a jury of six pu-
sons was regularly i_pa.elled and sworn to try the action,
which ended in the Petitioner and Respondents stipulating
as is set forth above, on the 31st d.y of July, 1974.
WHEREFORE. by virtue of Chapter SO, Colorado
Revised Statutes. 1963, as amended, the premises afore.aid ...,
the stipulation of Petitioner and Respondent..
IT IS ORDlUUID, ADJUDGED AND DECREED, That Petit111111:'.
have judgment condelln:tag for its use. that certain parcel "..
land described in Exhibit A attached hereto and incorporaN;
herein.
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IT IS PUR!HBa ORDERED, ADJUDGED AND DECREED, Tn..
Respondents, G. Paul Talbert and Winnifred S. Talbert,
recoyer from Petition.T, the sum of Three Thousand Dollar.
($S.OGO.OO) which au was deposited with the District Coul't
under the above captl~n.d action number on the date of
August 8. 1973, tOlether with Defendants court costs, jurr
.
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fees and expert witness f.... disbursed and incurred in
this action, taxed and aaounting to $___~sn
DONB AND SIGNED IN OPEN COURT. THIS~.J~AY OP
nr~^h.~ . A.D. 1914, NUNC PRO TUNC JULY 31, 1974.
BY TRE COt RT :
~
kUI'lALU J. HARDE.ST'!
JttDG'f,
DISTRiCT COURT
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MAURICE F FOX
ATTORNEY AT LAW
431S WADSWORTH BOULEVARD
WHEAT RIDGE, COLORADO 80033
TELEPHONE 424-4443
October 23, 1974
Mr. Bill McCarthy
City Attorney
City of Wheat Ridge
3760 Vance Street, Suite 305
Wheat Ridge, Colorado 80033
Re: City of Wheat Ridge
- G. Paul Talbert, et ux
Dear Bill:
Enclosed please find the following documents:
(1) Quit Claim Deed dated October 11, 1974,
runnlng between G. Paul Talbert and Winifred S. Talbert,
and the City of Wheat Ridge, a Municipal Corporation,
which has been duly recorded at Book 2672, Page 565.
(2) Stipulation and Rule and Order executed by
the Court on October 22, 1974, Nunc Fro Tunc to July 31,
197 4.
Your office should take the necessary action to
inform the County Assessors Office that this property was
acquired, nunc pro tunc to July 31, 1974, by the City of
Wheat Ridge and to remove the same from the tax rolls of
Jefferson County.
If you have any questions, please feel free to
contact me.
Very truly yours,
IllfU-~f~~
MAURICE F. FOX
MFF /me
Fncls,
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A parcel of land lying in the NW~ of the SW~ of
Section 22, T3S, R69W of the 6th P.M., City of Wheat
Ridge, Jefferson County, Colorado, more particularly
described as follows: Beginning at the southeast
corner of Lot 13, Talbert Subdivision, a recorded
plat in Jefferson County, Colorado, said point being
on the east line of the NW~ of the SW\ of said Sec-
tion 22; thence Soo06.3'W along the east line of the
NW~ of the SW~ of said Section 22 a distance of 56
feet to the TRUE POINT OF BEGINNING, said point being
614.72 feet south of the northeast corner of the NW~
of the SW~ of said Section 22; thence Soo06.3'W along
the east line of the NW~ of the SW~ of said Section 22
a distance of 77.42 feet to a point on the northerly
line of a parcel of land described in Book 2411 at
Page 924 of the Official Records of Jefferson County,
Colorado; thence NBoo29.B'W along the northerly line
of the parcel described in said Book 2411 at Page 924
a distance of 445.99 feet to a point 440 feet west of
the east line of the NW~ of the SW~ of said Section 22;
thence Noo06.3'E parallel to the east line of the NW~
of the SW~ of said Section 22 a distance of 61.54 feet
to the southwest corner of said Talbert Subdivision;
thence SB9046.1'E along the south line of said Talbert
Subdivision a distance of 292.50 feet to the southwest
corner of Lot 13, said Talbert Subdivision; thence
Soo06.3'W parallel to the east line of the NW~ of the
SW~ of said Section 22 a distance of 56 feet to a
point 613.3B feet south of the north line of the NW~
of the SW~ of said Section 22; thence S89046.1'E
parallel to the south line of said Talbert Subdivision
a distance of 147.50 feet to the TRUE POINT OF
BEGINNING.
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TELEPHONE 303/421.8480
Tf' ~ City of
......""'" 11.1 1_
lOGE, COLORAO~_~:::.. ..n~."~'JV71e (3, t
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3760 VANCE STREET. WHEA
OFFICE OF THE CITY ATTORNEY
4 November 1974
Jefferson County Assessors Office
1700 Arapahoe
Golden, Colorado 80401
Dear Sir:
Paul Talbert.
to 31 July 1974 via an
Court. Please remove
"The CarnClt[()ll Cl(V"
MAURICE F FOX
ATTORNEY AT LAw
4315 WADSWORTH BOULEVARD
WHEAT RIDGE, COLORADO 80033
TELEPHONE 424-4443
TO:
July 31, 1974
BILL MC CARTHY
FROM:
MAURY FOX
RE:
EMINENT DOMAIN PROCEEDING INVOLVING G. PAUL
TALBERT AND THE CITY OF WHEAT RIDGE.
The referenced eminent domain proceeding was
completed by settlement after one and one-half days of
trial to a Jury of six persons.
Settlement consisted of the following:
(a) Payment of $3,000 by the City of Wheat Ridge
to G. Paul Talbert and Winnifred Talbert.
(b) Agreement that the Talberts may retain a
buffering tract of land between their house and the
proposed Green Belt Park. Said buffering tract to con-
sist of a strip of property abutting the Talbert Lot
Number 13, and being 147.5 feet in depth and 56 feet ln
width.
(c) Agreement that the City of Wheat Ridge will
have the buffering area surveyed and will furnish the
Talbert's with a copy of said survey.
(d) Agreement that the City of Wheat Ridge will re-
place ~he fencing which the City wrongfully removed along the
rear of the Talbert's Lot Number 13. Said replaced fencing
to be chain linked fencing.
(e) Agreement that the City of Wheat Ridge will have
the common boundary existing between the park and buffering
strip fenced with chain linked fencing.
(f) City of Wheat Ridge to pay the expert witness
fees, court costs, and jury fees incurred by Respondents,
Talbert.
A completed stipulation and Rule and Order to be pre-
pared by my office and submitted to the Court for approval
within ten (10) days from July 31, 1974.
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To Bill McCarthy, ~y Attorney
CITY OF WHEAT RIDGE - MEMORANDUM
FromWard A. H-;;;ton, Director~
and Recreation Department
Date December 19, 1974
Subject BELOW
Approved
Date
CHAIN LINK FENCE TO BE INSTALLED ON PROPERTY OF
G. PAUL TALBERT,
RE: Your memo of December 13, 1974
The fencing specified in the stipulation and Rule and Order of the
District Court will be installed in the Spring of 1975. It has not
been installed to date, basically because there are no funds to
pay for the materials in the 1974 budget. Although a non-budgetted
item in 1975 we will be able to pay for the necessary materials.
Installation will be made by the parks maintenance crew, as their
schedule allows.
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TO: Mayor PBU~ " ~bramson
Alderman Mar'! Jo Cavarra
Alderman Louise F. Turner
Alderman Jos~ph M. Donaldson
Alderman Robert G. Howard
Alderman Cal"in O. Hulsey
Alderman Lawrence ~. Merkl
FROM: Office of thp. City ~ttorney
DATE:
SUBJ: Talbert Condpmnation Suit/Settlement
There follows a resL'me, and my reconmendations, above subject:
By Resolution #207, Council, on ?1 December 1972, directed the mayor,
and city attorney, ~r. Maurice Fox, to condemn property (approximately
45,173.5 square feet) owned by G. Paul and Wi~fred S. Talbert for--
greenbelt pu~~u~~s. It was then contemplated that the property was
o f a value of approyimately ~3,nnn.rn. It is assumed that Council
was informed of potential expenses aside from those of just paying
for the land.
Suit was filed and City took possession.
Certain fence(s) belonging to the Talberts were mistakenly removed
by the City.
Legal maneuvering ensued and expert appraisal witnesses were consulted/
employed.
City attorney tendered his resignation.
Trial was finally set Cafter postponements) for 13 and 14 February 1974.
City attorney left C"ty employment on or about 7 January 1974 and Mr.
William McCarthy assumed city attorney position.
In mid January, Mr. ncCarthy obtained full Council approval to hire
Mr. F ox to try case. Estimated fee, :\8110. on.
PAGE TWO
Mr. Fox and Mr. McCarthy confer; it had been learned that attorney
for Talberts had obtained prospective evidence that Talbert property
is worth more than 13,000.00.
Trial dates set over to 30 and 31 July 1974 because of the unavailability
of expert witnesses.
Mr. Fox confers witt1 City expert witnesses, engages in research and
further preparation.
In mid July, Mr. Fa,: learrf_ that City expert witnesses are thinking
thqt it may be necessary to raise their appraised value of the property.
Mr. Fox does more research.
Trial commences 30 July 1974. Evidence of it greater value is introduced.
Evidence of wrongfuJ fence removal is introduced. Evidence is introduced
that park patrons (particularly children) trespass on the remaining
Talbert property.
Shortly after noon, 31 July 1974, Alderman Turner, being informed of the
status of the case, suggested that a settlement be arrived at generally
along these lines: That only one-half the property be taken from the
Talberts at the oririnally determined price of $3,nOO.Oo; the remaining
one-half to be used a6 a buffer zone between the Talbert's residence and
the greenbelt; ~ restoration of removed fences; ~the border of the
buffer zone next abutting the Talbert's residence property be fenced
at City expense; anc that the~ matters of boundaries be determined by a
survey at City expense.
Alderman Turner's recommendations ~Iere generally agreed to by all parties
and Alderman Turner telephonically conferred with and obtained the
agreement a to the settlement of that number R of Aldermen to constitute
a majority.
Parties then specifically agreed and the court adopted as its findings:
(a) Payment of ~3,rnr.nn by the City of Wheat Ridge to G. Paul
Talbert and Winnifre~ S. T2lbert.
(b) Aqreemert that the T2lberts may retain a buffering tract
PAGE THREE
of land between their house and the proposed Greenbelt Park, ~aid
buffering tract to ~onsi6t of a strip of property abutting the
Talbert Lot Number 13, and being 147.5 feet in depth and 56 feet in
width (8,260 square feet, or 1/5 of iJ:J.f:' "ReI!::).
\(c) Agreement that the City of Wheat Ridge will have the
buffering area surveyed and will furnish the Talbert's with a copy
of said survey.
(d) Agreement that the City of Wheat Ridge will replace the
fencing which the City wrongfully removed along the rear of the Talbert's
Lot Number 13. Sairl replaced fencing to be chain linked fencing.
(e) Agreement that the City of Wheat Ridge will have the
common boundary existing between the park and buffering strip
fenced with chain linked fencing.
(f) City of Wheat Ridge to pay the expert witness fees, court
costs and jury fees incurred by Respondents, Talbert.
Mr. Fox has submitted a bill, which includes monies for his additional
work as set out above, in the amount of $1,075.00 (21~ hours at
$50.nn per hour) anrl the city's expert witness, Mr. Earl R. Baughar,
an appraiser, has submitted his bill for services in the_amount of
$1,050.nn (42 hours at $25.00 per hour). It is my opinion that such
bills are reasonable and the City Treasurer s~ax should be instructed to
pay them.
Mr. Fox (as of 13 August 1974) is preparing Rule and Order for the
Court's approval. ulhen this has become final (signed by the Court),
Ci ty ( ) should accomplish tl::l.a. furnishiR~ c:aplf Lu T dlLnts..,
o/ld OOCEl1'llFllw-n-~descr'ilJeQ, f!WIcing........ Jbe s.w:vey has been ordered,t ct
(!1:1 u9<..t-t:. .("U t,{ s#(~.&{. '"'-" "/ dAf;..(.t4:rs. .
Also, the City I receive a deed for the property.
I~ THl DISTPl[J COURT r~ AND FOR THF
COU~TY OF JEFFLRSON AND
qATI' OF COLORADO
Civil Action ~o 41S]'
CITY nF WHEAT RIDGF" a 'j
Municipal Cor?oration, of )
the County of Jefferson )
State ot Colorado, ~
Pet i t ioner' ,
and
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MOTrO\ FOR rOSTJNUA~rF
tj, PAUL TALBERT, WINIFRED S
TALBERT, PUBLl'= TRUSTIiB OF
THE COUNTY OF JSFFf:RSO~;, THE
TREASUREH OF T:ll: cou:ny OF
JEFFERSON, STATE OF COLORADO,
Respondents.
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COMES NOW, the City of Wheat Ridge ~y and
through its Attorney, Maurice F. Fox, and respectfullY
requests this Court for a continuance in the above
captioned case to a time certain to be fixed by the
Court ,
AliD t\S GROUNDS THEREFORE STATES UNTO THE I.OURT,
1. lhat Petitioner has been advised by its
expert witness that because of conflicting appointments,
concerning appraisal work with other governmental agencies,
he could not be available for testimony.
,
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That Petiti.oner has been advised that the
appraisal work Jone by ResponJents' appraiser would be
unavailable to the jury because he has conflicting appoint-
ments with other governmental agencies.
_._" v _
!J~l~~&J:<i~
AAUR!.E r. ,-,.)X
Attorney for Petitioner
4315 Wadsworth BoulevarJ
Wheat Ridge Colorado Rnn~~
.1, 2 4- 4;1 .i ')
IN THE llISTIUCT COURT U AND POR THE
COOl\lTY OF JEFFERSON AND
S't'ATE OF COLORADO
,~,'
Civil Action No. 41512
CITY OF WHEAT RIDGJ\.a Municipal
Corporation, of the e.unty of
Jefferson, State of eolorado,'
'e.ti tioner,
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~pondents. )
o R D E R
Vs.
G. PAUL TALBERT, WI~')!D S.
TALBERT, PUBLIC TRU OF
THE COUNTY OF JEFFE... . THE
TREASURER OF THE COUN.:, OF
JEFFERSON, STATE OF CqtORADO,
THIS MATTEl~..having come before the Court
on the Motion of the Petitioner, and the Court having
read said Motion and ~(JY being fully .ldvised in the
premises, hereby orders, the above capt.ioned case con-
tinued to the 3()<{.:J/ da}I'Jof __~___., 1974.
DONE A,1\.lD SIGIlli IN OPEN COURT, THIS Sa
DAY OF J~. A.D. 1974.
BY THE C(IURT:
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CERTIFICATE
I 'H~l'ebv cer! 1. fv ti:a t r naoded it true and
correct copy of the within ',lotioll for Continuance
and Order to the Attorney for Respondents, GenrRe \llan
dOilev, Attorney at La\'i, LHS WaJsworth Boulevard,
',"heat IUlg.~, '.01orado 8Uld3, this 4th Jay of F~bl'uarv,
.....n. 19-~.