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• <br />Case 1:05 -cv- 01738 -RPM -CBS Document 1 -1 Filed 09/07/2005 Page 3 of 7 <br />7. According to the organizational document on file with the Colorado Secretary of <br />State, the management of Solitario Purgatory, L.L.C., is vested in its members. <br />8. Based on information and belief, including inquiry of the Virginia State Corporation <br />Commission, Solitario Purgatory, L.L.C., is neither a citizen of the Commonwealth of Virginia nor <br />authorized to transact business there. <br />Jurisdiction and Venue <br />9. This Court has jurisdiction of this action pursuant to 28 U.S.C. § 1332(a)(1) because <br />(a) the amount in controversy exceeds the sum or value of $75,000.00, exclusive of interest and <br />costs, and (b) MLO is a citizen of the Commonwealth of Virginia while each of the defendants is a <br />citizen of the State of Colorado. <br />• 10. This judicial district is a proper venue for this action pursuant to 28 U.S.C. § 1391(a) <br />because each defendant resides here, because a substantial part of the events or omissions giving rise <br />to the claim occurred here, and because a substantial part of property that is the subject of the action <br />is situated here. <br />Factual Allegations <br />11. Prior to February 3, 2005, the Tatums jointly were the record owners of certain real <br />property located in Las Animas County, Colorado, known as Solitario Ranch and more fully <br />described as follows: <br />Township 33 South, Range 67 West of the 6d' Prime Meridian, approximately <br />152.701 acres located in Section 19, also known as Tracts III, IV, V, and VI, Chavez <br />Valley Ranch. <br />• —3— <br />