PERMFILE44354

• Permit No: M1986165
• IBM Index Class Name: Permit File
• Doc Date: 2/27/1987
• Doc Name: WILLOW BEND SANDPIT APPLICATION
• Media Type: D
• Archive: No

FOURTH CLAIM FOF. RELILiI' UNllER C.I:.C.P.
25. The averments of paragraphs 1 tlrrouglr 24
ated herein by reference.
2G. Plaintiffs are entitled to the entry of
pursuant to C.R.C.P. 65, including such mandatory ~
are required based upurr their allegations herein, pr
issuance of the land use approval by the Defendant Bo
Commissioners and further prohibiting the operation
errtraction operation as described in 86-210 by John
Sandco of Durango.
llliEREFOP,E, Plaintiffs pray that this Honor
them relief as follows:
e irrcorpor-
n injunction
rovisions as
hibiting the
ird of County
of the sand
~i11on, d/b/a
Court grant
A. On their First Claim for P.elief, for entr• or an Order
reversing tare decision of the Defendant Board of C urrty Couunis-
sioners acrd denying the land use application of John illorr, d/b/a
Sandco of Durango. ~
B. On their Second and Tlrird Claims for Re iei, for an
Order declaring that tl~e due process rights of P1 i.rrtiffs have
been violated and that the action taken by the Defen ant Board of
County Commissioners is null and void in its entirety.
C. On their Fourth Claim for Relief, for entry of an
injunction pursuant to C.R.C.P. 65 restraining the De endarrt Board
of County Commissioners from issuance of the land u e permit and
further restraining Defendant John billion, ci/b/ Sandco of
Durango from operation of the sand e:{traction opera ion proposed
in said application.
D. Plaintiffs also pray that this Ilonerable' Court grant
them recovery of their costs and attorney's fees e:: ended herein
and for such other and further relief as to the C urt may seem
just and proper in the premises.
Respectfully submitt
Address for Plaintiffs:
3009 County P.oad 250
Durango, CO B1301
DUI7CAN, DICKII7SON fi
/ 1 .,
1
1/ J /.
llavid L. Dic-inson, II04
Attorney for Plaintiffs
P. 0. Bor. 179
Durango, Colorado 3307.
[phone]
-4-
N, P.C.