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303 6595223 P. 05
<br />DISTRICT COURT, COUNTY OF WELD,
<br />COLORADO
<br />901 9u' Ave.
<br />Oteeley, CO 80631
<br />(970) 351-7300
<br />Plaintiff(s): SW TKO Joint Venture, LLC, a Colorado
<br />Litnited Liability Company, SW Villaneaux, LLC, s
<br />Colorado Limited Liability Company, and TKO, LLC, a
<br />Colorado Limited Liability Company..
<br />Defendant(s): Edith Chavers and Andrew Chavers,
<br />individuals and the Colorado Department of
<br />Transportation, adivision ofthe State of Colorado
<br />Attorney for Plaintiffs:
<br />Robert J. Bruce, Esq.
<br />Lawlis 8c Bruce, LLC
<br />1875 Lawrence Street, Suite 750
<br />Denver, CO 80202 ~ COURT USE ONLY
<br /> Case No. 2006cv391
<br />phone Number: (303) 573-5498
<br />Fax Number. (303) 573-553? Div.: Ctrm.:
<br />E-mail: www.lawlisbruce.com
<br />Atty. Reg, #: 17742
<br />COMPLAINT
<br />COME NOW, the Plaintiffs, SW TKO Joint Venture, LLC, SW Villaneaux, LLC and
<br />TKO, LLC, by and through their attorneys, Lawlis & Bruce, LLC, and respectfully submit the
<br />following as their Complaint.
<br />I. STATEMENT OF THE CASE
<br />1. Plaintiff, SW Villaneaux, LLC, owns real property historically known as the
<br />Porter Seepage Ditch, in Weld County, Colorado. SW Villaneaux, LLC, and TKO, LLC, owu
<br />property in Weld County, which barest from and use the Porter Seepage Ditch and the Ogilvie
<br />Ditch. SW TKO Joint Venture, LLC, is a Colorado limited liability company formed to develop
<br />the property owned by SW Villaneaux, LLC and TKO, LLC. Plaintiffs bring this action for,
<br />among other things, an injunction preventing the restriction of use of Plaintiffs' right to use the
<br />Porter Seepage Ditch which traverses State Highway 85 and Defendant Chavers' property.
<br />Additionally, Plaintiffs bring this action for an injunction preventing the restriction of the right to
<br />operate, maintain and repair the ditches In violation of Colorado law. Finally, the Plaintiffs being
<br />this action for declaratory judgment; for damages against the Defendants for trespass and
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