Notes: Difference between revisions

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Malicious Trespass - determine accuracy, and determine effort to achieve accuracy, and how location is determined.
builders open house
 
*Procedure for fence?
*Where fence?
*Accuracy of fence? Pin it.
*For the fence, would you put the posts entirely on your side?
*If so, where will the barbed wire be located?
*Size of main posts and interim posts? Size of corner posts such as between paddocks?
*Were you planning on a dividing fence between 2 paddocks?
*Were you planning on adding other paddocks ie additional corner posts?
*Wherearkers? 1000 and 800 feet
*How do you mark amline between?
*Did you use a transit?
*Absolutely Straight or curved, bends?
*Walk me through provedure for determining where you will clear?
*Do you allege that Plaintiffs are preventing you from building your fence?
*How are they preventing you?
*Did you ask Plaintiffs for permission to remove some boundary trees?
*Do you want to remove trees entirely on Plaintiff's land?
*If there is a dead tree, how far in do you want to remove it?
*What size are the largest boundary trees in feet?
*What size are the dead ones?
*How many live boundart trees do you want out?
*How many dead ones?
*Can you explain if there is a dead tree, how close to the boundary it would have to be for it to be a risk for your proposed fence?
*If branches can fall on it, you mean that you would take out any dead tree whose branches are above the fence?
*Are you saying, that if there were a 40' tree with canopy 40' wide, you would want to take it out of the trunk were 20' away from the boundary?
*Ideally, say you could do whatever you want, how far in to our land would you clear?
*Are you still asking the court to allow you to do this?
*Did Mr. Jakubowski approach you to tell you to stop your work on Feb 29?
*What did you say to him?
*Who else was there?
*Did Mr. Logston say anything?
*Youemtioned to Mr. Jakubowski on the first day of tree line work - what did you say?
*Did you inform me I that you can go on his land to do fence work?
*Is the temporary injunction preventing you from building your fence?
*If permanent injunction were not granted, what would.you do with the boundary trees?
*What would you do with dead trees that are up to 20 feet into our property?
*What would you do with live trees that are 100% on Plaintiff's land, but branches are on your land?
*Ask specific cases of what would you do in 3 cases. Trunk on you, branches on you. Trunk on you, branches on us. Trunk straddling, dead or alive. Trunk 100% on plaintiff - branches on you, alive. Same, dead. How do you determine limit  for distance from boundary for when you want to take out a live tree? How does that change for taking out a dead tree, if any?
 
 
Tube
*Where is it?
*How long is it?
*How much of it on your land?
*How much of it is on our land?
*Did you ask us for permission to locate it where you did?
*Are you saying that the tube is entirely on your land?
 
Excavator work day 1
*Where started, etc.
 
Euipment day 2-3
*What power equipment was involved? Dozer, backhoe, tracked skid, auger, chainsaw.
*How many machine hours on those days, any record?
*If no - roughly for the excavator on the 3 days?
*Roughly on the dozer?
*Roughly on tracked skid steer?
*What model chainsaw?
*How long does it take you to cut through a 12" diameter tree?
*How long does it take to cut through a 3' tree?
*Size?
*Model track hoe?
*Boom upward force or lift?
*Reach?
*Dozer model and size?
*Tractor pull or push?
*What are these tracks in this aerial?
*Draw the path of dozer on this picture?
*How many times did it go back and forth?
 
Bales
 
*What is the last haying date for Maysville?
Bales
*How do
 
you calculate bale yield for the parcel ?.
 
Flynn work
*Please take a look at Flynn receipt. Is that a true and accurate copy of receipt?
*Is this an authentic receipt?
*What was included?
*Was augering post holes included?
*Do you have other receipts, such as for the fence posts in the corner
*What are the three elements of a receipt ? What, cost, date.
 
Water
*Where is the hydrant for X Service located?
*How many hydrants are there connected to this service?
*How do you water the northern part of Tract?
*How do you water southern half?
*Point to North of Road part of Tract.
How do you water tract North of Road?
*Can you draw a boundary around northern tract? Southern tract?
*Are they fenced off from one another?
*Is there a gate between?
*How much did the events save you on water?
Cow Damages
*How did you calculate supplemental feeding damages
*What would it cost you to put up a temporary fence?
*What would a temporary fence look like?
*Cost?
*Labor?

Revision as of 12:58, 12 April 2025

builders open house

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