PERMFILE123728

• Permit No: M2005080
• IBM Index Class Name: Permit File
• Doc Date: 9/1/2006
• Doc Name: Motion to Dismiss
• From: Objectors Attorney
• To: MLRB
• Media Type: D
• Archive: No

08/09/2006 14:10 7190360200 ED FIART5FCRN .PAGE 02/06
EXHIBIT C

DISTRICT COURT, PARK COUNTY. COLORADO
Court Address: 300 4°i StreeL p.0_ Bmc 190. Faimlay. CO l04A0
PLAINTIFFS: NEIGHBORS FORA ~ ~I COM9INED (AURf
AESHtABLE PARK COUNTY, INC., AND

ROBERT CARGH.L, INDIVIDUALLX AND A5 AUG -' , 8 200fi
TRUSTEE OF THE CARGILL FAMILX TRUST
P~(OOUtrTY, C01.ORADO
DEFENDANTS: THE HEIRS ANA/OR
DEVISEES OF N.C. CARGILL ANA/OR LORA •COURT USE ONLY
E. CARGILL; JACK R. ALLEN AND SUSANNE
R. ALLEN; PARK COUNTY; $RUCE R. Case Number: 06-CV- al
PLANKINTON; PLANKINTON FAMILY
LIMITED PARTNERSHIP; RIVER RANCH Div.: B Ctrm.:
RESTORATION COMPANY, LLC.;
and ALL UNKNOWN PERSONS WHO MAY
CLAIM ANY INTEREST IN THE SUBJECT
MATTER OF THIS ACTION.
Attorney: Ed Hartshorn
Address: P.O. Hox 1502
Fairplay, CO. 80440
Phone Number. [phone]
Fax Number:. [phone]
E-mail: faimlavlawfa'~ahoo.com
A . R . #: 25402
COMPLAINT TO QUIET TITLE TO ONE-HALE OF THE OIL, GAS, AND OTHER
MINERAL INTERESTS IN REAL PROPERTY UNAER RULE 105
COME NOW the Plaintiffs; Neighbors for a Desirable Park County, inc., and Robert Cargill,
individually and as Trustee of the Carpal) Faatily Trust, by and through attorney, F.d Hartshorn,
and state and allege as follows:
1. Plaintiff, Neighbors for a Desirable Park County, Ine. has entered into a Contract with
Robert Cargill, both individually and as Trustee of the Cargill Family Trust (jointly
referred to as "CargilC'), authorizing Plaintiff Neighbors for a Desirable Pazk County,
lnc., to bring this Action both in its name, and also for "Cargill" by and through its agent
Kent Rolf.
2. Plaintiff, "Cargill" is the sole heir, endlor devisee and successor, of and to the interests of
N.C. Cazsill and/or Lora E. Cargill; "Cargill" therefore is the owner, (pursuant to the
reservation in that Warranty Deed recorded on July IS, 1963 at Book 180, Page 135, of
the Park County Records), of one-half of the oil, gas, attd other mineral interests in the