Laserfiche WebLink
were noC comglied with by Petitioner Three Bell Ranch, ae specified <br />heretofore. Said November 28, 1979, action was thereafter illegally <br />modified and/or changed, thereby voiding the original Resolution, <br />especially since Commissioner Thayer, who voted in the majority in <br />November, thereafter oppasad the changes in the conditions of approval. <br />8. ThaC that Intervenor's remedies at law are inadQquate. <br />WFIERHFORE, The Intervenor prays for judgment as follows: <br />1. For a decree pursuant to Rule 106(a)(4), C.R.C.P,, <br />that the rezoning action taken by the Respondent Board on November 28, <br />1979, and April 14, 1980, is void, arbitrary, capzicious, illegal and <br />beyond the discretion and jurisdiction of the Respondent Board. <br />Respectfully submitted, <br />Rv er[ ust n Dr scol ~5 29 <br />Attorney for Intervenor <br />1034 Logan Street <br />llenver, Colorado 80203 <br />Telephone: 832-2312 <br />Inte>•vsnar5c Address: <br />P.O, Box 1453 <br />Fort Collins, Colorado 80822 <br />CERTIFICATB OF PtAILING <br />I hereby certify that I mailed a true and correct copy of the <br />foregoing Complaint in Intervention by placing same in the United <br />States mail, postage prepaid, on the day of May, 1980, addressed <br />to the lollowinga <br />James McArdle <br />Mine Land Reclamation <br />Colorado Department of <br />Natural Rasourses <br />1313 Sherman Street, Room 423 <br />Denver, Colorado 80203 <br />Stephen J. Lauer <br />Hill and Hill <br />P,O, Box 421 <br />Fort Collins, Colorado 80522 <br />Attorney for Three Bell <br />Ranch Associates <br />-4- <br />