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JUN-15-2004 0854 DUNCRN,OSTRRNDERBD[NGESS 303 779 3662 P.0Bi53 <br />Page 210, a document recorded on August 20, 1968 in Book 307 at 700, a documerrt <br />~` recorded on October 31, 1966 in Book 297 at Page 14g, a document recorded on August <br />25, 1963 in Book 290 at Page 134of the records of the Clerk and Recorder of Clear Creek <br />Coumy. <br />h. Qwest Corporation f./Ir/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 443 and a <br />document recorded on March 12, 1907 of the records of the Clerk and Recorder of Cleaz <br />Creek Comity. <br />i. Geraldhte 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 S, <br />2002 in Book 642 at Page 730 of the records of the Clerk and Recorder of Clear Creek <br />County. <br />11. Insofar as it is known to the Petitioner upon exercising due diligence, there are no <br />other persons ar entities who may claim any right, title or interest in or to the Property or <br />interests described above. <br />r 12. Petitioner is informed and believes that this action does not affax the property of <br />any persons tinder guerdtanshIp or conservatorship. <br />13. The Petitioner has negotiated in good faith with the Respond~t-Landowners in an <br />attempt to acquire the Proporty and Water Right. The just compensation to be paid for the Property <br />and Water Right catulot be agreed upon and aegatiations 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 hrnnediate Possession Incorporating Legal <br />Authorities. <br />1S. The Respo~ems have a duty to take such reasonable steps under the <br />circumstances as will minimize their damages, if any. The Respondents cannot recover any <br />damages resulting from a failure to take such reasonable steps. <br />WHEREFORE, the Petitioner prays this Court ewer 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 etctetlt of their interests. <br />~. <br />4 <br />