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HomeMy WebLinkAboutpitkin.planning.273707400017 (4)DOCUMENT LAYOUT THIS FILE MAY OR MAY NOT CONTAIN ALL OF THE INFORMATION LISTED BELOW IN THE FOLLOWING ORDER Summary Sheet Resolution for the BOCC and /or P &Z Ordinance for the BOCC and /or P &Z Determination for the Hearing Officer Administrative Determination Staff Memo Application Public Notice, Acceptance Letter, Referral(s) Letter Site Plan Miscellaneous Plat copies (I 1x17) PAR CASE PROJ OWN /APP: Robert 8 Page Zan 3EP: Doug 8 Julie Prette FEES MTG DATE REV BODY Box 8114 Box 107 inne Aspen,CO 81612 PHI CIS M. Basalt CO 81621 PH ALLOCATED HOL 007 BY bI D 3p 6/2007 2/23/2 �`OTICED DATE OF FINALAQTI BOW Rem.- Ord: to rep 9/11/07/%bj/ /CDU 2437W OSED: 5p/2007 bj PLAT (BKPG . B64 P91 #541663 PLAT RECORDS 9/10/07 � VR APPROVAL DA TE" 'VRE -- R CASETYP;_ MinorAmendmenttoaDev lopmentl ,CASE CASE .:CASET(P6: CASE TYP3: - CASE TYPT. CASE TYP4: F Date Scanned: I File Location: on shalt Pz: HRG OFF HO INDEX I ADMIN: 029 -2007 ADMIN INDESC" 2007 Sjl/07 Board of Adjustment Case - -1 -17 November 25, 1968 %,1, R E S O L U T I O N WHEREAS, JESSE MADDALONE, filed petition for variance before the Board of Adjustment, Notice was duly given to surround- ing property owners and Public Hearing conducted at which the Board of Adjustment heard and took into consideration statements for and against granting of such variance, WHEREAS, the petition requested authority to enlarge by fourteen additional spaces the variance heretofore granted for the Smuggler Mobile Home Park, which was the subject of an action in the District Court of Pitkin County which culminated in consent decree, THEREFORE, BE IT RESOLVED That the Pitkin County Board of Adjustment does hereby grant a variance authorizing the enlargement of the Smuggler Mobile Home Park by I� not to exceed fourteen additional spaces, being the same spaces heretofore prepared or constructed, this variance being granted expressly subject to the terms, limitations and conditions imposed by the original Resolution granting variance for such trailer park, appearing in the minutes of this Board under the 19th day of April , 19 69, all of which, to the extent applicable are incorporated herein, BE IT FURTHER RESOLVED, That the provisions of this Resolution are not intended to vary or modify the consent decree heretofore entered in the District Court of Pitkin County concerning said mobile home park, and is expressly made subject to any interpreta- tion that may be placed on said consent decree by the District Court. 000001 ')� 12 11 3 ilaw. f.:.'l.�if...i vii.J:s1 u4 civil 1,,C%iC3n .iii. 34Cr5 T. MtNDALL0 i'lE2ilti�iv� VS. r}i :.Ii J.: yy Xl'alii.ON Ot DcfendanZa. 3 3 %. �T.c+Y—ZRy et al., pla:aaatifi3* / V5. et isci calGi;lnt� . CG: .S:a: s V. IS INAWLGR Comes on this datw upon mtLual ttii illation uiF".1 ay X�`K.':' =R.'Ri C7 8�.1 j'r�tY``.. «C'"S C:la '�`.i1L" �.GLt1: f°. C.tid:.f iRCl it)1,�.`..:'.k.12t,.x coaCent Decree in the *bovC C�jptlor�rcd action cmd the Cuutt L'Ci icily advised in the preaniles 9i1"Id3 05 f,ailo�s: jti:* l.h'.fi3.AS,, the def,,.tj-nta a.nd :Itron- t:ave pre- viously filed a petition or a?plieaat3an :or tl"e pjtjmt.in Cca:tty BUard OZ Ad'jcaats.Cnt, a COPY cf t9n4c'- is atC.Cs.id Ito plaintif£'a complaint and z. %zsed Exhibit "C "; the scx:dCCt =cu w'Lt«i respect to which tilo v.^.i:iance %is cc f"=11ted in cr-ai:s "lbod jas follows: 1.14 .1.14 in 453 ' mi , V.}A ;aCCt _L':'i %y r7. G: :1. ^. i.•.T..n �.k.� ��L�L'i:.:y :.+�. "�iC> 04 he vl:t'G P .E � i �. u:z a ::O:Ltt::�'y A :w t:i.th Cor,:7r U0. ,war♦ - ",O'.V4311 t;• 757.7 fC.C:t,�tt' Z; 2t. C452117" W to 36-- 4505.1,11 c'1• 224/�.1 �i: i.: `, <°.. it 4Di::1 ^i :',G. �rj t: ?::1,C.'•:: L0. .'r3� J 5 * i'•2 W. iJ4.cry. 1cCi to Gu4ani .na. Jy to c..a...e I I Li. �•?'if l't i'.. 165.37 6; �.. -, to co-a-2r '.:7. 7; 4. „- .y Af1•tC1 a.. �[��.� �Ct,4 v €J (,aracr A.6. i�1 4.;,'.I)4..'• aG• 4V tfJ r. G4 °a2' i�. v24 . C c} .:.arc or lese, to is r :i r place of horE in: fter referred to c' t:l�' t�5�.1.'sjt =wt d:rrrLl,l� ;;"1C, 1 Rai: v`:ia^J, Oil July `LO, 1 °i V.7, ♦ ♦a.xii 4LS,a4y 4'V++i 9N S� ft• +il :adopted a resolut;LOpp E411.ct1 ic: at1:r,C:LCd 'ns to ni niatiffa' Co plaint, which -rant Cd, to do c adcntc 1,1XJJalune and Strong, the riuht to con3t %C% a trailer cc-urt Ca tic 1"Id 3escribed rbove, the CvUrt t. t� n.� r�e;\.�•,yg� �tl ° +-� a'�.9 tT[^.n:" tTl' f� 't.; -�q�� �`r ?lluL : :t: ylr}� :;..:.:.e..US t.t �.wci, ♦.yly'N +t\,x i. d,A..i id::C,...... uwr 1. The plil n1't.1.f1'e"3 i.zl tii£3 ..,'�'lUVS.' CL:1 ZiO.:icd a— (;n cGf?acgt to the terms of said va— lJc -nco and cny objecti.6ia^ to its is a ice, rravided the foilowin- recuircl cats vr. r.cct by the I i defendants M,ddalDnc and S"rGr_Z: x?le i M2osed trailer ccurt rust cQ:.;91; with ail .zonin.,7 rc.vlatioas ^.,Overnir,3 rO�i1 le i1L 14'.3 CJi 't s 1C 2 in tl plt�iCJ L1iu ll re`rulataOnJ z;'curd „ pursucat thereto with the anir,::= lot size for trailers within the Subject area bcing Gtr feet by 70 fcct. OThe dcfe dnatc i'laddcalone and Vtrcnc' swill in- StZll a recreation area in t'.tict noxt!i%.�c: tcrly qua, "rant of :5tlt•jvct oreav :3Lhici1 will contain a picnic Znrca and ball 1�c1ds with ♦1(\. Lied0V W4i :Lm—,!rvY Wtt+L.�4 tJ� 6�IL'J cr1.;,ix%ally prc-..,.iaed to be ins`t -n11Cd at V�:4Z rd �� iS'wJr �4c.YCil hcari:lws prec6=eina t1 %o Or vcriti ace to Cite Zy.:encja:lts ,:!aad alone and Stri)i.c.- c. The boui+Iury Of till s-,I jcct -'rea wi .h Z" c=ce tions hcrcincfter noted wall be 'bordered wits a plsntiz; strip contains xoz7. of cvcrrecn tr :ea, w� zc :ate -2- 11111 I 19 �%W of which is not more t*,14-1 15 fcet ap art, mca -.-a cO irc�n t"a tran!T s. The trees will be pIrnted in €: st",:,- ,-,crc.'T. and will be not less than « feet in. at the ti: :e• cf pl.:nting. The defendants 2:addalons: aad Strong .srthor curce to =intain these trees in a healthy arc: in:� condition._ T`reso trees will ba placed on a placntinr stein of 20 feet in depth. (1) r ,ccnti =:n Iwo. 1: tlonm the boundary line 2.c:aia- after described as foliown: "A line located in Sc --tion 7, Tai:, ;w'ha 1,5 :,cati:, rt: n'., a 64 wc-4t tier.". the 6Lh i'.11. , 1"It -kin. Counit:y, Collncdo, more psrticulzrly describ--d as " %eginninZ at Corner Tio. 2 in the lca�.. cw ^crir.txo of the subject araaa, thence N. 54052'17" t7. 50.1 feet to Corner No. 3• thence H. 3 t'La'Sv'° 22 .1 fcaL to Corner .do. 4; tla°ence N. 33055'42" W. 1 =sfr.2 fcc c to Corner No. 5.1° the trees described above would be planted on the- property line and would of be its -Uarcd but would be placed 7 feet apart. in addition, zalong said LounJcry I I line a chain lints or :»cooler. rail fence four to vivo feet hiZh will be installed. (2) Excention tro. 2: The boundary line described as follows;: "A line located in the sou;.i:,.Ist r,,jzrtcr of Section 7, Township 10 Sait'14 7w r c 84 t:ert Of Li:;c 601 i P.iM, ritkin t,.':unt'y.colorado, bc,- Inonin, at Corr, -- !Z`O. 20 which is col acident with Corner : o. 5 of tf.c 01,, -�t Patent; then S. ae4714s" W. 750.7 icct to f:rsraor ;;o. 2. i stxall not be required to be tordrred by such ink or planting, strip, b:at r=y l:e 101% 45 it ncu d. The Court has heretofore czatercd a Conoc. t Greer providing that all t,:ailera and aobilo 4 secs 1, czted outside the variance lines of the subject area arc to be removed thirty (30) days .after the filiv, in Court of the -3- rezult£. of the survcy t l-ie ho :s a ^3 trailers cuf,;GiCa E;hc '.:'o: rdcry linos o ar n. That Order is Tait i':C::i,i:.Cti tQ prcvi4 o Ci:L is tLYC dLfCidaZ;C3 $c.T7L1„y and N..clLalv..e are to Y,:..: -Jtic .id U.... 1C..a by June 1, 1955. e. It is cl-r .ed 4i,i0a3 t+ir.' ti`s..'t i hi' re c-r -icta a drai zga problem with repel-« to lc- d conic' by ti:u pi lintiif Bucl7z—rn m i' tti-3,,� t :is r 2'ca- Thi icnu iss Llo_cl particularly described Cs the portion c, ho L "Placer. It is nareed beLwccn t1he t >i.:f'iicr, i;L:Ctr in i.:iC 4 v:-nt the County of Pitkin is unable or u : *dllinv to a1i vir:4c this drainage problem, the dp11 cndznt:3 w=trona ZnJ a3roo to put in a drain.:,© ditch tO %C� QF i1Tli Spa t;:i s rc ljtal no later t:zvn May 1, 1955. i. To secure t1he covplia.nae of the a;)ovo Cctioa o, dofa°nd.ants StronS and :i;ddalone c^,L5."t a to 0ot:c in a boY ?d in the =oant of $10,000.00 fro' a corporaLc su 'y, Soc. .. n,'.._', t' c parformzmcC of prcrphs 1(a) thro,, .. Ct 3 � l YL: C21WE Order. Such bond will run to eae bt:�tafit of the plairntlnf;,. In the event that paraS, -rnp ha l(a) taro: h 1(a) of this 01:41, r CVC, not cornAled with. ato=m. lishcd or per Qrrcd by VII Mnddalono arm Stror, by J`aly 1, 1:55, 01c terns of ;;,:ch tc-, :d :;ro to provide that tho surety trill cov-plete the u f3nl 11cd tnci tm- performed obliantnions ordered herein. 3. The defenm:7 its Strtin. z rand 1.zddaloac ;.crcia i:'L cr- dcred to pay $1,600.00 to the plaintiffs. 4. It is further ci*pressly oru'ored that „^,Ay teczp. r,,:;5 ? "oUlc..:is that rzy exist bet acn the parties cro. :.ot: rc!3oivCd by this Order and are not a part of this 1iti�atsan. •4- OOOOIp5 *, 5. The Court will continue to retain jurisdiction of these cases to insure compliance of this Court order. Upon compliance with this Decree, the above captioned matter is to be dismissed with prejudice, each party to pay their own costs. DONE IN OPEN COMT this !L_ day of 1965. BY THE COURT: flistrict Judge APPROVED AS TO CONTENT AND FORM: _ �_... Ac o : aq for Pia tif:a Attorney for defendants Maddalone and Strong Attorney for all other defendants Wo 1. -5- R E S O L U T I O N WHEREAS proposed Consent Decree has been filed with the Pitkin County Board of Adjustment in Civil Action No. 30406 now pending in the District Court of Pitkin County, bColorado, which decree has been examined in detail by C ,members of the Board of Adjustment, t 1; I a 000001 AND, WHEREAS, the said Consent Decree contemplates the granting of a variance from the provisions of the Pitkin County Zoning Resolution substantially in accordance with variance that was theretofore granted, and which became the subject of litigation, now sought to be resolved by said Consent Decree, AND, WHEREAS, the Board of Adjustment, by proper direction, has elected to treat said Consent Decree as a request and application for variance from the Pitkin County Zoning Resolution, and notice has been issued to all persons required to be served under the provisions of the Statute of Colorado and of the Pitkin County Zoning Resolution as adjacent property owners or otherwise, and public-hearing was duly scheduled and has been conducted, AND, TgHEREAS, the comments, objections and statements of all persons concerned and affected, who appeared at said hearing have been taken into account and considered, and The Board of Adjustment having jurisdiction herein, and being advised, I 000001 AND, WHEREAS, the said Consent Decree contemplates the granting of a variance from the provisions of the Pitkin County Zoning Resolution substantially in accordance with variance that was theretofore granted, and which became the subject of litigation, now sought to be resolved by said Consent Decree, AND, WHEREAS, the Board of Adjustment, by proper direction, has elected to treat said Consent Decree as a request and application for variance from the Pitkin County Zoning Resolution, and notice has been issued to all persons required to be served under the provisions of the Statute of Colorado and of the Pitkin County Zoning Resolution as adjacent property owners or otherwise, and public-hearing was duly scheduled and has been conducted, AND, TgHEREAS, the comments, objections and statements of all persons concerned and affected, who appeared at said hearing have been taken into account and considered, and The Board of Adjustment having jurisdiction herein, and being advised, I t� z: �Y THEREFORE, BE IT RESOLVED, by The Board of Adjustment of Pitkin County, Colorado, that the provisions of the proposed Consent Decree, copy of which has been filed herein and which is incorporated herein in all particulars by reference, are hereby approved. BE IT FURTHER RESOLVED THAT, the Board of Adjustment finds and determines that to now require termination and discontinuance of the Mobile Home Park involved in the appli- cation would create great hardship, not only to the property owners, but to the numerous residents therein, and would create a dire housing shortage and extremely difficult situation for many families and other persons involved, together with great financial loss and expense, for which reason the variance should be granted pursuant to and consistent with the terms of said Con.aent Decree. BE IT FURTHER RESOLVED THAT, the Board of Adjustment does hereby grant a variance from the provisions of the Pitkin County Zoning Resolution for the use and operation of a Mobile Home Park on the premises described in said Consent Decree, and the conditions specified for operation of said Mobile Home Park stated in said Consent Decree are hereby incorporated into this variance, and by reference made a part hereof, and that this variance is granted expressly subject to the conditions therein stated, and shall be subject to termination or revbo &tioho- in the event of non - compliance therewith. - 2 - J R E S O L U T I O N w WHEREAS proposed Consent Decree has been filed with the Pitkin County Board of Adjustment in Civil Action No. 30406 now pending in the District Court of Pitkin County, Colorado, which decree has been examined in detail by members of the Board of Adjustment, AND, WHEREAS, the said Consent Decree contemplates the granting of a variance from the provisions of the Pitkin County Zoning Resolution substantially in accordance with variance that was theretofore granted, and which became the subject of litigation, now sought to be resolved by said Consent Decree, AND, WHEREAS, the Board of Adjustment, by proper direction, has elected to treat said Consent Decree as a request and application for variance from the Pitkin County Zoning Resolution, and notice has been issued to all persons required to be served under the provisions of the Statute of Colorado and of the Pitkin County Zoning Resolution as adjacent property owners or otherwise, and public hearing was duly scheduled and has been conducted, AND, WHEREAS, the comments, objections and statements of all persons concerned and affected, who appeared at said hearing have been taken into account and considered, and The Board of Adjustment having jurisdiction herein, and being advised, 000009 u THEREFORE, BE IT RESOLVED, by The Board of Adjustment of Pitkin County, Colorado, that the provisions of the proposed Consent Decree, copy of which has been filed herein and which is incorporated herein in all particulars by reference, are hereby approved. BE IT FURTHER RESOLVED THAT, the Board of Adjustment finds and determines that to now require termination and discontinuance of the Mobile Home Park involved in the appli- cation would create great hardship, not only to the property owners, but to the numerous residents therein, and would create a dire housing shortage and extremely difficult situation for many families and other persons involved, together with great financial loss and expense, for which reason the variance should be granted pursuant to and consistent with the terms of said Consent Decree. BE IT FURTHER RESOLVED THAT, the Board of Adjustment does hereby grant a variance from the provisions of the Pitkin County Zoning Resolution for the use and operation of a Mobile Home Park on the premises described in said Consent Decree, and the conditions specified for operation of said Mobile Home Park stated in said Consent Decree are hereby incorporated into this variance, and by reference made a part hereof, and that this variance is granted expressly subject to the conditions therein stated, and shall be subject to termination or revocation in the event of non - compliance therewith. - 2 - aooaio Civil Action 1o. FTtkflf f f. Plotatiffst VS. oun 8sfeadmntsv rp advis" in tm rmasos t it in '.�':. #' .i 1 "..' t n::.` ✓`4 i ;itr P.a s ;ta: k1.. . k:�t by striki" the now Jaoes iisrkelunso viitrwnr it appears and iuu11 8istr t $: HENRY We No. 195CA. SUMMONS IN CIVIL ACTION. Bradford - Robinson Printing Company, 182466 Stout Street, Denver. Colorado HOWARD L.MAYER,RUSSELL He VOLK, JOHN ZUPANCIS,LEWIS P.HOLSTON, LOUIS SPAROVIC REMO LAVAGNINO, I GERALDINE HOBGOOD, Plaintiff$....... IN THE- - -DISTRICT - .........COURT IN AND FOR ............... ....COUNTY OF. ....... PITKIN................... AND STATE OF COLORADO Civil Aetion No .......................... ...........Div................. CREST GERBAZ,SAMUR HOWELL,and THOMAS J.SARDY,BOARD OF COUNTY COX MISSIONERS OF THE COUNTY OF PITKIN ; q&qg;lM=A&",the BUILDING IN- SPECTOR OF THE COUNTY OF PITKIN; JESSE MADDALONE; and GEORGE STRONG Defendant.S. ... .. SUMMONS THE PEOPLE OF THE STATE OF COLORADO TO THE ABOVE NAMED DEFENDANT........, GREETING: You are hereby summoned and required to file with the clerk an answer to the complaint within 20 days after service of this summons upon you. If you fail so to do, judgment by default will be taken against you for the relief demanded in the complaint. If service upon you is made outside the State of Colorado, or by publication, or if a copy of the complaint be not served upon you with this summons, you are required to file your answer to the com- plaint within 30 days after service of this summons upon yon. This is an actions See attached Complaint. Dated.. f ..v .......................1c4....... ----------------°------......----...-°-- - °----................... °-- °-° Clerk of said Court By.............. ............................... Deputy Clerk (Seal of Court) / 7 - Attorney for Plaintiff.... L90D First National Bank Build Denver, ..Colorado 80202 266- .. ......... ...... ......................... Address of Attorney Endedsummons is issued pursuant to Rule 6 of the Colorado Rules of Civil Procedure. If the summons Is imblbhed or served without a copy of ttim ,m upon tort the word "action" state the relief demanded. If body eu,se,tion is soaaht the summons must state. "rhh b an &AIDS +r , 00001 IN THE DISTRICT COURT IN AND FOR THE COUNTY OF PITKIN STATE OF COLORADO Civil Action No. = HOWARD L. MAYERs RUSSELL H. VOLK, ) JOHN ZUPANCIS, LEWIS P. HOLSTON* ) LOUIS SPAROVIC, REM LAVAGNINO, ) and GERALDINE H00GOODs ) Plaintiffs, ) vs. ) DREST GERBAZ, SAMUEL HOWELL, ) and THOMAS J. SARDY, --: ) BOARD OF COUNTY COMMISSIONERS ) OF THE COUNTY OF PITKIN#iENRY W.THURST)DN J!►iEB -iiAMKMWs the BUILDING ) INSPECTOR OF THE COUNTY OF ) PITKIN= JESSE MADDALONE; and j GEORGE STRONG, ) Defendants. ) COMPLAINT COME NOW the plaintiffs above -named and for claim the defendants state and allege as follcwss 1. Plaintiffs are residents and property owners of tkin County, Colorado. Henry W. Thurston 2. Defendant (hereinafter sometimes to as "Building Inspector ") is the Building Inspector Pitkin County, Colorado. 3. Defendants Orest Gerbas:, Samuel Howells and Thomas . Sardy are duly constituted members of the Board of County of the County of Pitkin, Colorado. 4. Defendants Jesse Maddalone and George Strong are of certain lands in Pitkin County, Colorado, and are operating a trailer court on said lands. , 3 5. The defendants Jesse Maddalone and George Strong originally commenced to operate said trailer court because of the grant of a variance made by the Pitkin County Board of Adjustment by resolution dated July 26, 1963. A copy of said resolution is attached hereto and marked Exhibit "A ". 6. That the subject area to which the said variance was purportedly granted is described as follows: "A tract of land located in the SE /4 of Section 7, Township 10 South, Range 84 West of the 6th P.M., Pitkin County, Colorado, more particularly described as follows: Beginning at Corner No. 1 which is coincident with Corner No. 5 of the East Aspen Patent; thence S. 34047143" W. 757.7 feet to Corner No. 2, thence N. 54052'17" W. 58.1 feet to Corner No. 3; thence N. 39045'58" W. 224.1 feet to Corner No. 4; thence N. 33055'42" W. 164.2 feet to Corner No. 5; thence N. 000'15" E. 165.37 feet to Corner No. 6; thence N. 56004'18" E. 293.85 feet to Corner No. 7; thence N. 43052' E. 73.16 feet to Corner No. 8; thence N. 28005' E. 40.6 feet to Corner No. 9; thence S. 69052' W. 424 feet, more or less, to Corner - No. 1, place of beginning." (hereinafter referred to as the "subject area "). 7. That the subject area was on July 26, 1963, and is now zoned R -15, according to the Pitkin County Board of County Commissioners Resolution establishing land use zoning districts, and the "Zoning District Map ", incorporated into said resolution, originally adopted on June 5, 1955, and as subsequently amended. 8. That Zoning District R -15 does not permit use of, land within such district for purposes of trailer courts. 9. The terms of the variance (Exhibit "A) provide s follows: "1. The proposed trailer court mist comply with the zoning regulations governing such courts in Pitkin County and the minimum lot size for trailers in this proposed shall be 40 feet by 70 feet. 00001 -2 102. The appellants shall landscape the area as they have promised in their appeal. "3. If the proposed trailer court is not completed within six months of July 26, 1963 the variance shall be void." 10. The terms and conditions of the said variance were not complied with by defendants Maddalone and Strong, in that the trailer court does not comply with the zoning regula- tions of Pitkin County, the trailer court was not completed within six months and the area is not landscaped as required. 11. On March 23, 1964, the Pitkin County Board of Adjustment declared said variance was and is null and void. The provisions of C.R.S. 1953, as amended, 106 -2 -24, provide that it is unlawful to maintain or use any land in violation of any regulation and /or any of the provisions of any county resolution pertaining to zoning. Thurston 12. The defendants 36a3aes and the Board of County Commissioners of Pitkin County, Colorado. are charged with the enforcement of the Pitkin County zoning resolution pursuant to the terms therein and pursuant to the statute on county planning found at C.R.S. 1953, as amended, Chapter 106, Article 2. 13. Said plaintiffs and others have by letter dated April 15, 1964, demanded that the Building Inspector and the Board of County Commissioners enforce the applicable zoning re- solution and prevent the defendants Maddalone and Strong from continuing to violate the Pitkin County zoning resolution by operating a trailer court in a zoning district which does not permit such a use. 14. Said defendants, Building Inspector and Board of County Commission rs, have failed and refused to enforce the 0000 5 «3.. tkin County Boning resolution as required by lm. 15. plaintiffs have no plan and adequate legal remedy and suffer property damage and deprivation of property values by the continuing violation of the Pitkin County toning resolu- tion. WHEREFORE, plaintiffs demand relief in the nature of and ask that the Court order the Building Inspector and the Board of County Commissioner& to compel the defendants Maddalone and Strong to cease use of the subject area as a trailer court in violation of the Pitkin County toning resolution - for judgment for costs and for such other relief as may seem just in'the premises. Address of all Plaintiffst Colorado 0000 DAWSON* NAGEL9 SHERMAN & HOWARD /s/ RAYMOND J. TURNER Is/ JOHN A. BENNETT Attorneys for Plaintiffs 1900 First National Bank Building Deaver, Colorado 80202 266 -3401 r4r 9 IKS— ,i `,_ f "yy-. Civil ACtion I o.r i. :L.f Yir 3'C COME "W the plafatt ffs (ex part*) and now to snood ft t. 0006"7 IN too i A'. ni' g_ Vr ki iii Jp:! AD t< x -• i. :L.f Yir 3'C COME "W the plafatt ffs (ex part*) and now to snood ft t. 0006"7 SMUGGLER TRAILER PARK VIOLATIONS Violations of Consent Decree of District Court of County of Pitkin, Civil Action No. 3406, 19 April, 1965. Section 1.(a) No maps are on file showing location of minimum lot sizes for trailers of 40' x 70', per Consent Decree. Section 1.(b) No recreation area containing picnic area and ball fields have been installed. Section 1.(c) The boundary of the trailer park has been incompletely bordered with required planting strip, and present planting not in accord with requirements of Court Consent Decree. GOO, U-18