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Answers to Interagatories

Essay by   •  May 29, 2012  •  Study Guide  •  515 Words (3 Pages)  •  1,936 Views

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IN THE CIRCUIT COURT FOR BALDWIN COUNTY, ALABAMA

HARRY T. BRADLEY and )

EMORY BRADLEY )

)

)

Plaintiffs )

)

vs. )

)

) No. G3233P

HONEY LOU CARTWRIGHT, )

FRANK BRADLEY, )

GUY DOWLING, )

GULF SHORES GAS COMPANY, AND )

WILLIAM O. SIMS )

)

)

Defendants )

ANSWERS TO INTERAGATORIES

GUY DOWLING, having been dully sworn, submits the following answers to interrogatories propounded to him by Defendant's in the above hyphen styled case.

1. In your answer you state that you or your predecessor entitle constructed and maintained a sewer line through the described premises. Who was your predecessor entitle and where is such dead of record?

ANSWER: To the best of this Defendant's knowledge, information, and belief the sewer line through the described property was constructed by a plumber under contract with WILLIMAN N. MILLS JR. whose dead is of record in book 1404, page 332, register's office for Baldwin County, Alabama and is dated May 25 1965.

2. When did you and your predecessor entitle secure a tap to the main sewer line and from whom did you secure such tap?

ANSWER: To the best of this Defendant's knowledge, information, and belief the tap rights to the main sewer line were acquired by Mr. and Mrs. WILLIMAN N. MILLS JR. Twenty-four years ago. This Defendant acquired the tap rights under dead from NICK H. GRENNE and wife MERLEAN H. GRENNE dated March 23 2000 of record in book 3368, page 504, said register's office, convened land described therein, together with the appurtenances, estate, title, and interest there to belonging, which included right to use the main sewer lines serving alcoal corporation subject to the provisions in the agreement with alcoal corporation.

3. On what property was said main sewer line?

ANSWER: The main sewer line extended along Palm Hill Pike on or along the public right away and also was on other property from its origin to the termination of the alcoal plant.

4. Please state fully what agreement or understand you had with

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