post trial brief - AboutForsyth.com
post trial brief - AboutForsyth.com
post trial brief - AboutForsyth.com
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were filed one year apart, both represent that they are original versions with no revisions. Both<br />
represent that they were reviewed, signed off and approved within just a few days of being submitted.<br />
Together, they make conflicting representations as to the use of the Common Area, so that the<br />
developers and the County could show to various government entities whatever picture they wanted to<br />
present at in any given circumstance.<br />
14.<br />
Plaintiffs Exhibit 43 and Defendants' Exhibit 1 both show that the entire Ivyshaw Landing<br />
subdivision (18 Lots) has responsibility for operation and maintenance of the installed Community<br />
Septic System. However, in contravention of the intent of the County Commissioners, the Ivyshaw<br />
Landing Covenants have been unilaterally modified by the subdivision developers to fraudulently<br />
remove from responsibility of maintenance those lot owners who have individual septic systems<br />
installed.<br />
15.<br />
Defendants' have incurred expenses on behalf of all of the homeowners in the subdivision<br />
which the Plaintiffs have refused to acknowledge because of their stated desire to ignore the problems<br />
of the subdivision, for their own personal benefit. Those expenses include:<br />
A. Rindt-McDuff Associates, engineering:<br />
7/6/2007 $2,500.00<br />
10/16/2007 $210.53<br />
3/10/2010 $5,552.74<br />
5/14/2012 $780.00<br />
Total: $9,043.27<br />
B. Mill Creek Environmental Services:<br />
11/9/2012 $1,176.00<br />
C. Total Surveying, in support of RMA investigation:<br />
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