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DISTRICT COURT, COUNTY OF WELD, STATE OF COLORADO
Civil Action No. 91 CV 684 Division 1 i0Tk'" ',.
SUMMONS
VILLA WEST MOBILE HOME PARK PARTNERSHIP,
a Colorado general partnership,
Petitioner,
v.
WELD COUNTY BOARD OF EQUALIZATION AND THE WELD COUNTY ASSESSOR,
Respondents.
The People of the State of Colorado
To the Respondents named above:
You are summoned and required to file with the Clerk of
this Court an Answer or other response to the attached Complaint
within twenty (20) days after this Summons is served on you in
the State of Colorado, or within thirty (30) days after this
Summons is served on you outside the State of Colorado.
If you fail to file your Answer or other response to the
Complaint in writing within the applicable time period, judgment
by default may be entered against you by the Court for the
relief demanded in the Complaint, without any further notice to
you.
The following documents are also served with this Summons:
COMPLAINT.
Dated this day of September, 1991.
LOHF, SHAIMAN & ROSS
A professi nal Corp Itti+oonn
By:
St� 7�
ephe E. KapniL , #7810
950 South Cherry Street #900
Denver, Colorado 80222
(303) 753-9000
Attorneys for Petitioner
This Summons is issued pursuant to Rule 4, C.R.C.P. , as amended.
A copy of the Complaint must be served with this Summons.
I
at / r ri<, e r: . (_ 4 FJ%e_, 911406
DISTRICT COURT, COUNTY OF WELD, STATE OF COLORADO
Civil Action No. 91 CV
COMPLAINT
VILLA WEST MOBILE HOME PARK PARTNERSHIP,
a Colorado general partnership,
Petitioner,
v.
WELD COUNTY BOARD OF EQUALIZATION AND THE WELD COUNTY ASSESSOR,
Respondents.
The Villa West Mobile Home Park, for its complaint against
Respondents Weld County Board of Equalization (the "Board") and
the Weld County Assessor (the "Assessor") , states and alleges as
follows:
1. The Villa West Mobile Home Park (the "Owner") is the
owner of, and is responsible for payment of the 1991 real
property tax payable in 1992 with respect to certain residential
real property, consisting of land (the "Land") and improvements
(the "Improvements") thereon, located in Weld County, Colorado
(the Land and Improvements may be collectively referred to as the
"Property") identified as Weld County parcel No. 095901106017,
PIN No. 1654686, known as the Villa West Mobile Home Park.
2 . For purposes of the 1991 real property assessment, the
Assessor valued the Property at $2, 722, 275.
3 . The Owner timely appealed to the Board the Assessor' s
1991 Notice of Determination. A copy of the Owner' s appeal to
the Board and the Assessor's Notice of Denial are attached hereto
as Exhibit 1.
4 . After a hearing, the Board by Resolution dated August
7, 1991 denied the Owner's appeal of the Assessor' s 1991
valuation of the Property. A copy of the Resolution is attached
as Exhibit 2 .
5. This action is brought in accordance with C.R.S. 1973
Section 39-8-108, as amended, for trial de novo of the valuation
for assessment purposes of the Property.
7. The Owner has timely complied with all conditions
precedent to bringing this action.
8. The Owner asserts that the actual value of the Property
for 1991 real property assessment purposes is no more than
$1, 363 , 000.
WHEREFORE, Petitioner Villa West Mobile Home Park prays that
this Honorable Court grant its petition, find that the actual
valuation of the Property for 1991 real property assessment
purposes is $1, 363 , 000 or such lesser amount as may be shown at
trial, direct the Weld County Board of Equalization and the Weld
County Assessor to value the Property for 1991 assessment
purposes accordingly, and grant such other and further relief as
is just.
DATED: September 4, 1991.
LOHF, SHAIMAN & ROSS
A professional corporation
Robert Shaiman #3510
Stephen E. Kapnik #7810
John C. Steele #13477
By: Z . ` r ^/6__
950 South Cherry Street #900
Denver, Colorado 80222
Telephone (303) 753-9000
Address of Petitioner:
4891 Independence Street #140
Wheat Ridge, Colorado 80033
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