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much clay in that clay was collecting at the bottom of the
cushion and on top of the base. This problem created unsafe
conditions for the horses and the jockeys, and, in early
September 1991, the guild of jockeys boycotted the track for fear
for their safety. In response to this boycott, the TRC asked Mr.
Moore to inspect the track to ascertain whether it was safe.
Mr. Moore and his assistant, Joe Fallwell, inspected the
track in September 1991, and they concluded that soft spots in
the track made the track unsafe. During their inspection,
Messrs. Moore and Fallwell pulled back the track's cushion and
found that clay was breaking away from the base and rising into
the cushion. The consultants recommended that the entire cushion
be "peeled back" and screened to remove most of the clay. This
was done. The entire cushion was peeled back and run through a
screening process, and, after fresh sand was added to the
cushion, the newly filtered cushion was layered back onto the
track. After this process was complete, the track was considered
safe for racing, and Trinity resumed its racing activities
shortly thereafter.
Beginning on or about December 18, 1991, and continuing for
approximately the next 4 days, heavy rains fell in Willow Park,
and significant portions of the Property were inundated by a
major flood that spewed raging water onto it and damaged the
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Last modified: May 25, 2011