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-' . . DISTRICT COURT, LARIMER COUNTY, COLORADO Case No. COMPLAINT DEAN G. ANDERSON AND BETTY JO ANDERSON, Plaintiffs, v, THE HANDY DITCH COMPANY, STATE OF COLORADO, THE UNITED STATES OF AMERICA, AND ALL UNKNOWN PERSONS WHO CLAIM ANY INTEREST IN THE SUBJECT MATTER OF THIS ACTION, Defendants. For a complaint against Defendants, Plaintiffs state: GENERAL ALLEGATIONS APPLICABLE TO ALL CLAIMS FOR RELIEF 1, Plaintiffs are residents of Larimer County, Colorado. 2. Defendant Handy Ditch Company ("Handy") is a Colorado mutual irrigation corporation, whose principal place of business and legal address is Berthoud, Colorado, in Larimer County. 3, The United States of America, acting through the Farmers Home Administration, United States Department of Agriculture, may claim some interest in the subject matter of this action as mortgagee under a real estate mortgage granted by Handy and recorded in Book 1891 as Page 707 of the Larimer County records, . 4. Defendant State of Colorado, acting through the Colorado Water Conservation Board, Department of Natural Resources, may claim some interest in the subject matter of this action by virtue of a warranty deed recorded as Reception No. 85064275 of the Larimer County records, 5, There may be persons interested in the subject matter of this proceeding whose names are unknown to Plaintiffs although diligent efforts have been made to ascertain the names of said persons; such persons have been made Defendants and designated as "all unknown persons who claim any interest in the subject matter of this action"; so far as Plaintiffs know, the interests of any such unknown persons are derived through the named Defendants hereof. 6, Subject to the rights of Plaintiffs, Handy owns and operates a reservoir known as Hertha Lake or Reservoir whose circumference or outer boundary is described in EXhibit A, attached hereto and incorporated herein by referenCe. C ~?l1ot~,