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<br />parties, both Petitioner and Respondent, is, or may be, inadequate <br />in that the Findings and Resolution of the Respondent Board of <br />Commissioners of the County of Larimer dated November 28, 1979, <br />(attached hereto as Exhibit A and incorporated by reference herein) <br />has been subsequently changed and/or modified on or about April 14, <br />1980, in violation of the Rules of Procedure of Larimer County, <br />Sections 1.2, 1.7, 3.6, 7.1 and the Larimer County Comprehensive <br />Zoning Resolution, Section 24.7. (See attached Exhibits B and C). <br />5. That Movant has absolute right to intervene pursuant to <br />Rule 106(a)(4) since, if there was a final ruling, it occurred on <br />April 14, 1980. (See attached Exhibit D), <br />6. Further, Movant prays leave of this Court to intervene as <br />a Plaintiff in this cause pursuant to Rule 106(a)(4) to assert a <br />claim involving questions of law and fact common to the main action <br />as shown in the proposed complaint attached hereto. <br />7. That by reason of the above and foregoing, this Court <br />cannot determine the controversy between the parties now before it <br />without prejudice to the rights of the Movant; that Movant is a party <br />necessary for a complete determination of the controversies herein. <br />IJHEREFORE, Plovant prays for leave to intervene in this action <br />against both Plaintiff and Respondent and for leave to file the pro- <br />posed Complaint in Intervention, and for such other and further relief <br />as the Court may deem proper. <br />Dated this day of May, 1980. <br />Respectfully submitted, <br />Robert Justin Driscoll # 72 <br />Attorney for Intervenor <br />1034 Logan Street <br />Denver, Colorado 80203 <br />Telephone: 832-2312 <br />