STATE OF SOUTH DAKOTA
COUNTIES OF MCPHERSON, SPINK, }
BROWN, AND EDMUNDS )
)
388
IN CIRCUIT COURT
FIFTH JUDICIAL CIRCUIT.
PETER HELFENSTEIN. JR,, ROTT
FARMS. INC., KETTERLING FARM, LLC,
VILHAUER LAND LIMITED
PARTNERSHIP, BRIAN HOFFMAN THE
DAVID AND VALERIE RATH LIVING
‘TRUST, COLIN AND MARY BETH
HOFFMAN, IFROME (i, HOFFMAN,
MICHAEL AND NANCY KLIPFEL,
ALDEN AND WILMA FLAKOLL,
SHANTEL C. SCHUMACK, LEROY AND
JOAN WEISZHAAR, and WADE AND
IUDY WEISZHAAR,
Plaincifis,
SCS CARBON TRANSPORT LLC, wikia
SUMMIT CARBON SOLUTIONS,
Defendant.
SCS CARBON TRANSPORT LLC,
Plaintiff,
GERALDINE H. SAYLER JORDRE,
DENNIS WOLFE, QUINTON WOLFE, R &
CFEICKERT LAND LLC, REBECCA D.
MICHATLSOHN, DAVID MELLAND.
ROTY RANCH LIMITED PARTNERSHIP.
THE ROGER E. MEYER AND
ELIZABETH 1, MEYER REVOCABLE
LIVING TRUST, SUSIE K, ‘TREFTZ,
PAMALA KESSLER. GARY AND
SHIRLEY WOLFF LIVING TRUST.
WILLARD HE RVINA W.
DECLARATION OF
DOMINIQUE SALGADO.
45C1V22-000014
45C1V22-000018
Filed: 5/17/2023 4:57 PM CST Brown County, South Dakota 06C1IV22-000253MBIER, KEN STUGELMAYER, MARSHA.
M. VOSSLER, THE MARK M. VOSSLER
AND MARSHA M. VOSSLER
REVOCABLE TRUST, MARILYN D.
NELSON, MARK THOMPSON. THE.
ESTATE OF ALBERT FUGENE
ERDMANN, CHARLES E.
SCHAUNAMAN. JEROME R, WALL, THE
VIRGINIA L. BREITAG LIVING TRUST,
and SIEH FARMS, LLC
Defendants.
BRAUN FAMILY TRUST 2020. B&L
FISCHBACH FARMS, MARGARET
ELLETT LIVING TRUST, KEN OLSON
TRUST 2010, OLSON FAMILY TRUST.
2019, FRANCOLI Fal ‘
PARTNERSHIP, FISCHBACH REAL
ESTATE LP, ED AND JOELL
FISCHBACH, ARMADALE LIMITED.
RTNERSHIP, PAUL FISCHBACH
TRUST 2012 & DAWN FISCHBACH
TRUST 2012, J&S PARTNERSHIP.
MYRON 0. HAMMER CREDIT SHELTER
TESTAMENTARY TRUST, and JAMES
AND ALTA SMITH,
Plainciffs,
SCS CARBON TRANSPORTLLC, a
Delaware Limited Lisbility Compan;
SUMMIT CARBON SOLUTIONS.
Dererwlant
JARED BOSSLY. BOSSLY REAL ESTATE
LIMITED PARTNERSHIP, KENNETH
AND DIANNA SHAFER, ESTATE OF
DONALD A, SCHAUNAMAN, CRAIG
SCHAUNAMAN, KIRK SCHAUNAMAN,
(OYE DAHME,
ID AND DONNA _}
7ACIV22-000047
O6CTV22-000253
Filed: 5/17/2023 4:57 PM CST Brown County, South Dakota 06C1IV22-000253ROZELL, SCOTT ROZELL, DENNIS AND
JEAN HASELHORST, MILTON AND
RHONDA HASELHORST, SETH KLIPFEL,
and MICHAEL AND NANCY KLIPFEL,
Plaintifis,
SCS CARBON TRANSPORT LLC,
Delaware Limited Liability Company, a/k/a
SUMMIT CARBON SOLUTIONS,
Detiendant.
DELORES SCHUMACHER REVOCABLE
‘TRUST, and JOHN AND STEPHANIE
JUNG,
Plaintiffs,
vs 22C1V22-000020
SCS CARBON TRANSPORT LLC, aka
SUMMIT CARBON SOLUTIONS,
Defendant
i
DECLARATION OF DOMINIQUE SALGADO
1, Dominique Salgado, cestfy to the best of my knowledge that the statements set forth i
this i re true and correct
rent
| Lam over 18 years of age, am of sound «ind and body, and am under no legal
disability. Uhave personal knowled ze ofthe fuetssct forch inthis dechiration, aud if ealled to testify
in potsom about those facts, could and would do so competently and wader oath,
Filed: 5/17/2023 4:57 PM CST Brown County, South Dakota 06C1IV22-0002532, Tam asuivey crew member with TRC Companies (TRC). TRC has been contracted
by Sumumit Catbon Solutions. LLC to perform surveys on behalf of SCS Carbon Transport LLC
(SCS) in connection with the development of SCS"s pipeline in South Dakota.
‘ew Chief, Andrew Roberts, and F were dispatched 10
3. On May 3, 2023, my
perform surveys on Jared Bossly's property in Brown County, South Dakota, We estimated that
the surveys would take 30 minutes co complete.
4, When wearrived at Mr. Bossly’s property, Mr, Roberts and I went up to the house.
There were approximately nine vehicles parked at the house. We knocked on the door several
times, but no one answered, We then walked to a shop building on the property and knocked on
its door, but there was no response there either.
5. Afterthese attempts, we drove down the road to the point on Mr. Bos
"s property
where we intended to enter (o begin the surveys,
6 Aswe begen to enter the property on foot, a woman drove down from the house.
She was speaking to someone on her cell phone. She asked us if we were surveyors for Summit,
We told her that we were. She told us that we were “not wanted here.” She said that her husbavdd
was on the phone and was on his way to the property
7 The worn put her husband on speakerphone so we could speak (o fim, L
undctstood him to be Jared Bossly, Mr. Bossly told us thatif we performed thie surveys, wenecded
to make sure that we left the property in good condition and did not leave any trash. Mr. Roberts
assured him that we would not feave any trash behind
8. The Mi. Bussly chet stated tous that, when get there, Put kiling the fist reson
Ise.”
Filed: 5/17/2023 4:57 PM CST Brown County, South Dakota 06C1IV22-0002539. At that point, | became concemed for our safety, as did Mr. Roberts. Mr. Roberts
asked Mr. Bossly’s wife if it would be safe for us to go ahead and complete the surveys. She
refuased to answer and repeated that her husband was on the way.
10. Outof concern forour lives and safety. Mr. Roberts and {left the property without
completing the surveys
11. To date, wehave not completed surveys on Me. Bossly’s property duc to his threat
that he would kill us,
[SIGNATURE PAGE FOLLOWS]
Filed: 5/17/2023 4:57 PM CST Brown County, South Dakota 06C1IV22-000253I declare under penalty of perjury under the law of South Dakota that the fo}
and correct.
ESN. SPs_
Signed on the | {day of May, 2025.
r
Filed: 5/17/2023 4:57 PM CST Brown County, South Dakota
United States,
06C1IV22-000253