Alan Hudson's Proposed Findings and Conclusions - University of ...

Case 1:10-cv-00487-WMN Document 201 Filed 11/14/12 Page 4 of 9
18. The cow barn area was designed to drain water towards the manure pit located at
the head of Ditch 3. The slope of the cow barn area is angled so that the water runs towards that
manure pit in order to make it easier to clean up the dairy operation. Id. at 78: 4 - 80: 5.
19. Cows drink approximately 100 gallons of water a day. Cows defecate on average
50 to 60 pounds a day. Id. at 84: 3-10.
20. Annual cow manure production on the farm is 500 to 600 tons. Id. at 87: 2-7.
21. The Fall of 2009 into the Winter of 2010 was an extremely wet time period.
Because the pastures were wet, Mr. Hudson set up bedding on the cement area near the old
feeder in the cow barn area so that cows could have a dry place to go to if they chose to. In the
time period between the Fall 2009 and Winter 2010, every cow went every day at least 2 to 3
times a day to the water trough located in the cow barn area to water. Id. at 87: 8 - 89:6.
C. Construction of the Chicken Houses
22. Mr. Hudson was 19 years old when the chicken houses were built. He used the
100 acres that his parents deeded to him as collateral to borrow the money from Farm Credit to
build the chicken houses. Id. at 89: 7-17.
23. Mr. Hudson has not yet paid off the Farm Credit loan, and probably has another
$50,000 more to pay off. Id. at 89: 21- 90: 2.
24. Mr. Hudson decided to build the chicken houses because poultry growing was
going to be his contribution to the farm, as there was not enough work to support him and his
family without the poultry operation. Id. at 90: 3-8.
25. Wayne Toll, a local contractor on the Eastern Shore, built the chicken houses for
Mr. Hudson based on cookie cutter designs. Mr. Hudson did not design the houses. Mr. Toll
obtained building permits for the chicken houses. Id. at 90: 21 - 91: 17.
2430524.1 38449/112351 11/14/2012
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