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.5 ~, <br />.~ •' 'r ~ III I II I II I II IIII III • y~~ ~ ~ : a <br />~.~~ii ;: ., ~yoJ <br />IN THE DISTRICT COURT '~ ' ~ ~~' ~~ ~' ~ ~,(?. ~ <br />IN AND FOR THE COUNTY OF LARIMER <br />STATE OF COLORADO <br />Civil Action No. 79CV1141, Division I <br />THREE BELLS RANCH ASSOCIATES, <br />a Colorado co-partnership, <br />Plaintiff, <br />vs. <br />THE BOARD OF COUNTY <br />COhQtISSIONERS OF THE COUNTY OF <br />LARIitER, AND THE COUNTY <br />PLANNING COMMISSION OF <br />LARIMER COUNTY, <br />Defendants, <br />vs. <br />VALERIE SCHUMANN, <br />Intervenor. <br />MOTION TO INTERVENE <br />COMES NOW the Movant, Valerie Schumann, by and through her <br />attorney, Robert Justin Driscoll, and moves this Court for leave of <br />this Court to intervene as an Intervenor ici this cause <br />pursuant to Rule 24(a) and (b), C.R.C.P., for the following reasons: <br />1. That the Movant owns residential real property immediately <br />adjacent to and bordering on the "Three Bells Ranch." <br />2. That the zoning of said "Three Bells Ranch" is the subject <br />of the Petition for Judicial Review before this Court. <br />3. That Movant, by reason of owning contiguous land, has an <br />interest in the subject zoning matter in the above-entitled action <br />and such interest may be adversely affected by the judgment rendered <br />therein. <br />4. That the representation of the Movant's interest by existing <br /> <br />