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0, P <br /> 1 IL <br /> District Court, County of Pitkin, State of Colorado <br /> Case No. 97 CV 13 1-1 <br /> MOTION FOR LEAVE TO FILE AND SERVE A SUPPLEMENTAL <br /> PLEADING AND TO JOIN ADDITIONAL PARTIES <br /> Page 3 <br /> 5. By virtue of its regulatory authority and police powers as more fully set out in the <br /> proposed Pitkin County's Answer to Amended Third-Party Complaint, attached hereto and <br /> incorporated by this reference, Pitkin County is so situated that disposition of this claim for <br /> injunctive relief in Pitkin County's absence may impair or impede Pitkin County's ability to <br /> protect its interest. <br /> 6. Mid-Con Realty, L.L.C., is a Colorado limited liability company, and is properly <br /> subject to service of process. <br /> 7. Defendants have alleged in paragraph 48 of their Amended Third-Party Complaint <br /> that property subject to the Reclamation Plan in Coal Basin has been transferred to Midcon <br /> Realty, L.L.C. and that the transfer of the property to Midcon Realty, L.L.C. was on the express <br /> condition that the Creditors' Trustee would protect property values by preventing destruction of <br /> certain improvements. <br /> 8. As the owner of the property, Midcon Realty, L.L.C. is so situated that disposition <br /> of this claim for injunctive relief in its absence may impair or impede Midcon Realty, L.L.C.'s <br /> ability to protect its interest. <br /> WHEREFORE, Pitkin County respectfully requests that it be realigned as a Third-Party <br /> Defendant, that it be permitted to file and serve by mail on all parties hereto its Answer to the <br /> 3 <br />