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Wherefore,Pitlan County requests the following: <br /> a. Under the First Claim for Relief, for a declaration that the Plan <br /> requires payment of Pitkin County's outstanding taxes from sales <br /> proceeds of property subject to the tax, prior to distribution of such <br /> proceeds to other creditors, and that all real property and improvements <br /> of Mid-Continent within the area described in schedule 7863 was and is <br /> subject to Pitkin County's lien for taxes due under schedule 7863. <br /> b. Under the Second Claim for Relief, for damages for breach of <br /> contract for Defendants' failure to pay Pitkin County any portion for <br /> taxes outstanding as personal property and improvements were sold, in <br /> an amount to be established at trial. <br /> c.. Under the Third Claim for Relief, that the Trustee provide an <br /> accounting of sales and sales proceeds of Mid-Continent's personal <br /> property and improvements previously located in Pitkin County. <br /> d. Under the Fourth and all Claims for Relief. for an order that <br /> Defendants pay, from the escrow proceeds, all amounts which the <br /> accounting indicates should have been paid to Pitkin County from the <br /> proceeds of sales, in satisfaction of the judgment for breach of contract; <br /> and that the balance of escrow proceeds be used to pay real property <br /> taxes under schedule 7683 and that the Trustee pay any remaining <br /> personal property taxes due to Pitkin County from the proceeds of future <br /> sales of personal property subject to the lien for such taxes. prior to any <br /> other distributions under the Plan. <br /> e. For Plainitft's costs herein, and such further relief as the Court <br /> deems appropriate. <br /> Respectfully submitted this !!:2 day of 1997. <br /> Pitkin Countv Attorney's Office: <br /> By: <br /> Deborah Quinn, #7685 <br /> Assistant Pitkin County Attorney <br /> 530 East Main Street, Suite 302 <br /> Aspen. Colorado 81611 <br /> (970)920-5190 <br /> 6 <br />