HomeMy WebLinkAbout1934-006 Stipulation - Fred C Homes & Susanne Homes Carter
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19 34
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Gus Nerebtu7 J
Attu at Law
Medford, Egon
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i Gust:
Enclosod herewith plo ase find Resolution which has heretofore been
duly passed by the Board of Directors of the Talent Irrigation District
whereon they agree to deliver five acre feet of the water heretofore
f purchased by the City of Astiland to Fred C. gomes at the hoodgatea on
his pmPe rty.
The Irrigation District wish that Mr. Hem" would mew pquent for his
proportion ate shares of the maintenance to the City of Ashland and they
wilt annually bill us for our share of the maintenance on the whole Boo
acre feet which we had heretofore purchased*
Since we have built a measuring device wherer your t,'lients, Fit C.
gmes and Susanne Homm Carters, secure their agreed portion of cno -fifth
of the present gates flow of said spring, std. as the installation of
this device together with the enclosed Resolution from the Board of
Factors of the Talent Irrigation District, ac plri.sh in offset the
purposes autline d i r: our stipulation, we trust that it will be satis-
factory to your clients for us to draw up s satisfaction and agresmAnt
whereby this perforuace mW be accepted in lion of the performance out-
lined in the st pa2ation- Ttorsupon the suit =W be di.am -teed without
prejudice.
Awaiting further advice we remain
VW7 truly yours
aRIG i; BRIGGS
FW,T J. VAS' DYKE
BY
FJV
lvss
IN THE CIRCUIT COURT OF THE STATE OF OREGON
IN AND FOR JACKSON COUNTY
CITY OF ASHLAND, a )
municipal corporation,
Plaintiff, )
VS. ) STIPULATION
FRED C. HOMES and )
SUSANNE HOMES CARTER, )
Defendants. )
)
WHEREAS, the above named plaintiff and the above named
defendants have heretofore executed and filed of record in
this court a Stipulation as a basis for settlement of the
above entitled matter in the above entitled court and cause,
by the terms of which the respective parties stipulated and
agreed by and through their attorneys to do certain things,
the performance part of which is now found to be impossible:
NOW9 THEREFORE, IT IS HEREBY STIPULATED AND AGREED by
and between the City of Ashland, a municipal corporation,
acting by and through its attorneys, BRIGGS & BRIGGS and FRANK
J. VAN DYKE, and Fred C. Homes and Susanne Homes Carter, acting
by the through their attorney, GUS NEWBURY, as follows:
1. That the defendants relinquish to the plaintiff all
claim to four-fifths (4/5) of the aggregate flow of water from
what is known as the Berkeley Spring, being the spring involved
in this suit, said flow being estimated at approximately twenty
(20) gallons per minute.
2. That the plaintiff relinquish all claim to one-
fifth (1/5) of the aggregate flow of the waters of said spring.
3. That the plaintiff give and grant unto each of the
defendants the right to tap any pipe line now existing or which
may be installed by plaintiff, with a three-quarter (3/4) inch
tap, for the service of the dwelling of the defendant Fred C.
Page 1. Stipulation
Homes and for the service of the Awelling of the defendant
Susanne Homes Carter, or for any future dwelling of each* or
their successors, which shall take the place of those now exit-
ing, said taps to supply water from said plaintiff's pipe line
for household use such as bath and toilet fixtures and for water-
of stock, but not for any irrigation, and said use on each ser-
vice tap is not to exceed the aggregate amount of two hundred
(200) gallons per day.
4. That the plaintiff install at its expense suitable
equipment and measuring devices so as to furnish the defendants
with one-fifth (1/5) of the flow cf said spring at oppromimately
the point where diversion is now made, said one-fifth (1/5) flow
of said spring to be understood to be in addition to the service
taps mentioned above.
3. That in the event the plaintiff should succeed in
increasing the flow of said spring at some future date over the
said present flow, estimated as being twenty (20) gallons per
minute, that the said 1.vslntiff is to have all of the benefit
of said increased flow.
6. That the plaintiff, as compensation to the defend-
ants, agrees to secure from the Talent Irrigation District a
Resolution by Its Board of Directors, waiving any objections
said Talent Irrigation District may have to the delivery by
the City of Ashland of not to exceed five (5) acre feet of
water annually at the headgate of the Fred C. Homes farm in the
Bellview District near Ashland, Oregon, the said five (5) acre
feet being part of the waters of the Talent Irrigation District
heretofore contracted for by the said ';ity of Ashland, and its
delivery to the said Fred C. Homes farm to be on the some terms$
stipulations and conditions as exist in that certain contract
between the `-ity of Ashland and the Talent Irrigation District,
recorded in Volume 163 at pages 101-10) of the Jackson County,
^ag 2. Stipulation
Oregon, Deed Records, and the said Fred C. Homes and Susanne
Homes Carter and their heirs and assigns stipulate and agree
to pay annually to the City of Ashland their proportionate
share of the maintenance charges for the said five (5) acre
feet of water under the terms and conditions of the said con-
tract between the City of Ashland and the Talent Irrigation
District, recorded as aforesaid.
7. That all of the above mentioned terms and conditions
which were to have been done and performed by the parties here-
to prior to this date, have been done and performed, and that
this stipulation is entered into between said parties for the
purpose of causing the record to conform to the facts; that
upon the acceptance and execution of this stipulation by the
parties hereto, this cause shall be dismissed without costs to
either party.
DATED this ___day of , 1934.
Attorneys for Plaintiff
ATTORNEY FOR DEFENDANTS