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October 31, 1966 in Book 297 at Page 148, a document recorded on August 25, 1965 in <br />Book 290 at Page 134of the records of the Clerk and Recorder of Cleaz Creek County. <br />h Qwest Corporafion f./k/a Mountain States Telephone and Telegraph <br />Company, is named as Respondent because it may claim an interest in the Property by <br />virtue of a document recorded on February 11, 1993 in Book 213 at Page 445 and a <br />document recorded on Mazch 12, 1907 of the records of the Clerk and Recorder of Clear <br />Creek County. <br />i. Geraldine Thompson, in her official capacity as Treasurer of Clear Creek <br />County, is joined as a Respondent pursuant to C.R.S. § 39-3-134. <br />j. Geraldine Thompson, in her official capacity as Public Trustee of Clear <br />Creek County, is joined as a Respondent by virtue of a document recorded on June 5, 2002 <br />in Book 642 at Page 730 of the records of the Clerk and Recorder of Clear Creek County. <br />11. Insofaz as it is known to the Petitioner upon exercising due diligence, there are no <br />other persons or entities who may claim any right, title or interest in or to the Property or interests <br />described above. <br />12. Petitioner is informed and believes that this action does not affect the property of <br />any persons under guazdianship or conservatorship. <br />13. The Petitioner has negotiated in good faith with the Respondent-Landowners in an <br />attempt to acquire the Property and Water Right. The just compensation to be paid for the Property <br />and Wa[er Right cannot be agreed upon and negotiations have proved to be futile. <br />14. The Petitioner requires immediate possession of the Property and Water Right as <br />that term is used in the Colorado eminent domain statutes and Colorado case law. The Petitioner <br />has filed contemporaneously herewith a Motion for Immediate Possession Incorporating Legal <br />Authorities. <br />I5. The Respondents have a duty to take such reasonable steps under the circumstances <br />as will minimize their damages, if any. The Respondents cannot recover any damages resulting <br />from a failure to take such reasonable steps. <br />WHEREFORE, the Petitioner prays this Court enter Orders as follows: <br />1. That if ownership or interests in the Property and/or Water Right are not correctly <br />set forth herein, the Respondents be required to set forth by Answer the extent of her, his, its or their <br />respective interests and the names and addresses of any other interested persons or entities and the <br />nature and extent of their interests. <br />2. That the just compensation to be paid for the acquisition of the Property and Water <br />Right be detennined in the manner provided by law. <br />