GENERAL40745

• Permit No: M1981148
• IBM Index Class Name: General Documents
• Doc Date: 12/24/1983
• Doc Name: VERIFIED COMPLAINT
• Media Type: D
• Archive: No

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L11P!ED LFi~D AEC! ! ~Y1A?IGN DR~ISIOPI LcC , ~ ~~} ~ ~ ~ ' d
83~;V011251 Celo. GCJi. of P!aiur.l Resources
DISTRICT COURT, CITY AND COUNTY OF DENVER, STATE OF COLORADO
DEC ° (! 1983
Case No.
VERIFIED COMPLAINT
Division No. ;~
CTTY OF LAKEWOOD, a Colorado municipal corporation,
Plaintiff,
v.
COLORADO MINED LAND RECLAMATION BOARD; COLORADO DEPARTMENT OF
NATURAL RESOURCES, MINED LAND RECLAMATION DNISION, STATE OF
COLORADO; and ROBINSON BRICK COMPANY, formerly known as ROBINSON
BRICK ~ TiLE COMPANY, a Colorado corporation,
Defendants.
COMES NOW the Plaintiff, City of Lakewood, by and through its attorneys,
Gorsuch, Kirgis, Campbell, Walker and Grover, and for its Complaint against the Defen-
dants states as follows:
GENERAL ALLEGATIONS
1. This is an action for declaratory judgment under C.R.C.P. 57, for a show
cause order under C.R.C.P. 106(aX4), for judicial waiver under the Colorado
Administrative Procedure Act, C.R.S. 1973, 5 24-4-10, et seq. for breach of contract, for
fraud and misrepresentation and for exemplary damages.
2. Venue is proper under C.R.C.P. 98 and 1978 C.R.S. 24-4-106(4), as amended.
3. The Plaintiff, City of Lakewood (hereafter "City"), is a municipal corporation
duly organized and existing under the laws of the State of Colorado, with offices at 44
Union Boulevard, Lakewood, Jefferson County, Colorado.
4. The Defendant Mined Land Reclamation Board (hereafter "Board"), is a part
of the Office of the Executive Director of the Colorado Department of Natural
Resources.
5. The Defendant Robinson Brick Company, formerly Robinson Brick be Tile
Company (hereafter "Robco") is a corporation organized and existing under the laws of
the State of Colorado.
6. The Defendant, Colorado Department of Natural Resources, Mined Land
Reclamation Division, is an agency of the State of Colorado.