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HomeMy WebLinkAboutW 32nd & Youngfield (Richter) CITY OF WHEAT RIDGE - MEMORANDUM To City Attorney Fox From Ci ty Cle rk Subject Dwaine Richter Lawsui t AllIlBxatlon 1\10. 5 Date 1/5/77 Approved Date Enclosed are certified copies of the following for Annexation No.5 at W. 32 Ave. and Youngfield: 1. Minutes Transcript and Minutes of 2/13/75 and Resolution No. 374. 2. Minutes Transcript and Minutes of 7/21/75 and letter from Arthur Brunton. 3. Proof of publication of Ordinance No. 171 (Published 2/18/75 and July 31, 1975). Public Hearing Notices for Outline Development Plan (Published 6/19/75 and 7/3/75) Public Hearing Notices for Preliminary and Final Plans (Published 8/19/76 and 9/9/76) 4. Minutes Transcript and Minutes of 9/27/76. 5. Minutes Transcript and Minutes of 10/11/76. 6. Ordinance No. 171. All of the action on this same parcel of land in 1974 do not apply to this case in my opinion. Please verify. (See attached Motion File card on this property). -..-.- " 644863 g 6 rr:, (' c:~C') 'fH 0') ~ - 0 Ci ::n INTRODUCED ~-< a - . A BY Turner .., (T1 ..... ~ A ...' ~..~ c., (X) po .. ..,J :0, ",' e? n ORDINANCE NO. 152 o~r ;;;0' W 0'''' ...' .- Series of 1974 ;;;0 J L.: I , , TITLE: AN ORDINANCE TO ANNEX CERTAIN TERRITORY TO THE CITY OF WHEAT RIDGE. BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF WHEAT RIDGE, COLORADO, THAT: Section 1. That all the requirements, except the passage and adoption of this ordinance, have come to pass to annex the hereinafter described real property to the City of Wheat Ridge, which now permits the City Council to adopt and pass this ordinance. Section 2. That the following described real property, situate in the County of Jefferson, State of Colorado, be and the same is hereby annexed to the City of Wheat Ridge, to wit: '\ Beginning at the northeast corner of Lot 1, Block 1, Applewood Gardens Subdivision, Jefferson County, Colorado; thence N 0 degrees 48.2' W along the easterly line of Lots 2, 3, 4, 5, 6 and 7 of said Block 1 8 distance of 488.43 feet to the north- east corner of said Lot 7; thence continuing N 0 degrees 48.2' W a distance of 50 feet to the northerly line of West 33rd Avenue; thence S 89 degrees 39' W along the northerly line of West 33rd Avenue a distance of 92 feet to the southeasterly corner of the west 30 feet of Lot 5, Block 4 of said Applewood Gardens Subdivision; thence N 0 degrees 48.2' West along the easterly line of the west 30 feet of said Lot 5 a distance of 130 feet to the north line of said Lot 5; thence 5 89 degrees 39' W along the northerly line of said Block 4 a distance of 211.03 feet to a point 1062.48 feet west of the east line of Lot 15, Roxbury Gardens, Jefferson County, Colorado; thence N 0 degrees 31.3' W parallel to the east line of said Lot 15 a distance of 205 feet to the north line of said Lot 15; thence N 89 degrees 39' E along the north line of said Lot 15 a dis- tance of 728.38 feet to a point 334.1 feet west of the north- east corner of said Lot 15, said point being on the westerly right-of-way line of Interstate Highway No. 1-70; thence southerly along the westerly right-of-way line of said Highway for the following four courses: 5 6 degrees 3705' W a distance of 119.2 feet; S 0 degrees 3D' E a distance of 266.70 feet; S 89 degrees 40' W a distance of 32.8 feet; and S 6 degrees 31' W a distance of 547.73 feet to a point 70 feet north of the so~th line of the NW 1/4 of Section 29, T3S, R 69 W; thence S 0 degrees 17 3/4' E a distance of 70 feet to the south line oflthe NW 1/4 of said Section 29; thence N 89 degrees 43.5' E along the south line of the NW 1/4 of said Section 29 a distance of 456.57 feet to the southeast corner of the SW 1/4 of the NW 1/4 of said Section 29; thence S 0 degrees 36' E along the east line of the W 1/2 SW 1/4 of said Section 29 a distance of 60 feet; thence S 89 degrees 43.5' W a distance of 687.84 feet to a point 635 feet east of the west line of the SW 1/4 of said Section 29; thence N 0 degrees 39.5' W parallel to the west line of the SW 1/4 of said Section 29 a distance of 15 feet; thence S B9 degrees 43.5' ~ parallel to the north line of the SW 1/4 of said Section 29 a distance of 240 feet; thence N 0 degrees 39.5' ~ a distance of 45 feet to the north line of the SW 1/4 "..-3" 29"'; ,,;~ '(j -~ ( ( 2631 2~j8 of said Section 29; thence N 0 degrees 48.2' W parallel to the west line of the NW 1/4 of said Section 29 a distance of 30 feet to the north line of West 32nd Avenue, as shown on the plet of said Applewood Gardens Subdivision; thence N 89 degrees 43.5' E along the north line of West 32nd Avenue a distanae of 50 feet to the intersection of the south line of said Lot 1 with the west line of said Lot 1; thence N 0 degrees 48.2' W a distance of 95 feet to the northwest corner of said Lot 1; thence N 89 degrees 43.5' E along the north line of said Lot 1 a distance of 115 feet to point of beginning. Section 3. The Clerk of the City shall perform all statutory duties to complete said annexation. Section 4. The owners of one hundred per cent (100%) of the property have petitioned for annexation. Section 5. Effective Date. This ordinance shall take effect and be in force thirty (30) days after publication following final passage. INTRODUCED, READ, ADOPTED AND ORDERED PUBLISHED AND POSTED on first reading by a vote of 5 to 0 this 11th day of April , A.D., 1974. READ, ADOPTED AND ORDERED PUBLISHED AND POSTED on second and final reading by a vote of 5 to 0 this 2nd day of May , A.D., 1974. ,,' \, I ), ~ t ; \ '" \ ~ ; I) 1\ ~b~??'~ . ~~k? Pau fl. Abramson, MaljDrr_ - . . 6<<_4,r- P9. 'f Jj..._ I '~~L.J..t~If'-N' ~ , \ \ ,I, .-i. ~"jl: I , ~ ' 6 4 4 8 6 4 / I: l , ~ 1"!. -i F C iLi J 1 : I," "--( ~~ -" z~-: .),-~~ .. "<.., ~. c_ 'j- '" JUH G 08 d1 ' l4 .. r''' IUUU!!" ill .:J........_".,. c "~, ~ r ,Ii ' . '~'t .c.k - ,;J.td I - f3 ::.!;!7 6 4 4 8 6 3 L' { ~ ~1 ~ , s r t, r L FILeD I"~ iAl " _ ~: N :,00 j; : I '" ~ G ~~ t <.., ~- \ JUH 6 I 07 r'M 'N \ r - T- .' P ~ ._'1 1////,,'((/ WHEAT RIDGE PLANNING COMMISSION August 26, lSJ7/1 Minut es Special meeting of the Wheat Ridge Planning Commission was called to order at 6:30 P.M. bV Chairman Leland Stewart in the Albert E. Anderson Community Building, 4355 Field Street. ~ Members of the Commission present were: Cal Jenks, Mickey Harlow, Bonnie Scoma, was Zoning Administrator Dennis Wigert, heard, and other interested citizens. Leland Stewart, Dr. Otto Bebber, and Garth Gibbons. Also attending repTFcsentatives -of the cases to be CASE NO. WZ-74-l8 Dwaine Richter, northwest of intersection of 1-70 and West 32nd Avenue. Mr. Wigert made the following comments and recommendations: 1. Zoning Amendment Request - Planned Commercial Development 2. Approximate Area - 10 acres 3. Contiguous zoning - east - 1-70 west - unincorporated north - unincorporated south - unincorporated 4. Contiguous land use - east - Commercial west - Residential north - Vacant south - Residential 5. The parcel is not in the designated Flood Plain. 6. The parcel is presently vacant. The Planning Department makes the following comments and recommendations: 1. The applicant has submitted an outline development plan. A decision must be rendered concerning rezoning to PCD. Intensive scruting of the plan should occur at the Preliminary Development phase. 2. The State Geologist has concluded the parcel has no commercially valuable mineral deposits. 3. The proposed uses described in the developer's statement are generally consistent with Commercial One zoning. One exception is the indoor warehousing, a Commercial Two use. 4. An irrigation ditch traversing the property will be relocated to follow along the west property line. This area will be planted, and with the surplus water, dense vegetation will grow providing a buffer effect for the residential area to the west. ' 5. Several design alternatives have been discussed with the developer. Depending upon uses approved, the appropriate overall design will be incorporated in the Preliminary Plan. 5. The Planning Department recommends that the Outline Development Plan be approved for the following reasons: 1. The Land Use Plan does not cover this area. The Planning Department recommends the parcel be zoned commercial because of its proximity to 1-70. 2. Planned Commercial Development will insure optimum uses and design. Mrs. Harlow asked if letters were sent to adjacent property owners who were opposed to the case. Mr. Wigert stated that they were notified by hand carried letters. Dwaine Richter, 2850 Berry Lane, Golden, Bsked if the property was properly posted. Mr. Wigert stated that it was. Mr. Richter stated that the intent of the request is to have a Planned Commercial Development, beginning with the Outline Development Plan, and progressing to the preliminary and final stages. Intended use is for a unique center. Mr. Richter has submitted a soil test which states that there are no economically minable gravel areas. He stated that the site will be a benefit to thR City and t,hR Cr1l1nty in LoIR~1 nf t8xe8. Nr. Richter steted thet he feels the site should be commercial. The reason for the change in zoning is that there has been a recent substantial change in charactRr in thR nRiahhnrhnod which blRrrents ~ -------- such a change. Mr. Richter cited the 900 acre rezoning case of Coors from Agricultural to Industrial. Mr. Richter stated that sound studies which have been submitted indicate that the area is already at a commercial or industrial level. Mrs. Harlow asked Mr. Richter to explain what has happened to the property since he aquired it. Mr. Richter stat1P that in 1966-1968, the previous owner and developer of Applewood Gardens, tried to rezonf3 the property Residential Two. He failed at this and sold the property to Mr. Richter in 1968. At this time, Mr. Richter felt that it was commercial area. Proposed to the citizens a service station and convenience store on West 32nd Avenue and PRQ on the northern part of the lot. The neighbors objected to the commercial area so they changed the plans and made it all apartments. The neighbors objected to the density so they cut the density down and went before the Jefferson County Commissioners. The Planning Department approved the plan unamiously but the Commission disapproved the plan unamiously. Two years later he applied for annexation to Wheat Ridge contigent to commercial zoning. Council tied and the request died. In 1973 he applied the same way, subject to zoning and Council passed the request for annexation and zoning Commercial One, and Restricted Commercial One for the north- west area by a vote of 4-2. Neighbors made a legal protest and sued the city. They asked the judge to reverse the decision. Case was dropped and Mr. Richter reapplied. Dr. Bebber asked Mr. Richter to go over the restrictions placed on his praoos8d uses at the last Planning Commission meeting. Mr. Lewman asked if Mr. Richter would add, "automobile, campers, and trailers~, to item 10. i page 3. Mr. Richter agreed to this addition. Mary Dodder, 3238 Zinnia Court, stated that she worked with the property owners association with Coors, and the land is still Agricultural. She stated that the land is planned for a Planned Development for lakes, and is not zoned Industrial. Mrs. Dodder explained the. development for the 11 lakes and the surrounding area to the Commission. She stated that Coors initially planned to rezone the area Industrial, but they received a lot of neighborhood opposition so they agreed on a Planned Development for lakes. She stated that Coors is no~mining gravel out of the area, and that it will take approximately 10 to 12 years to clear out all of the gravel. Mrs. Dodder stated that there is a piece of property on West 32nd Avenue which is zoned Agricultural One. There is a posting sign on the property requesting a change to MR-l zoning. She stated that they are proposing 70,000 square foot lots for single family residence. Mr. Gibbons stated that he did not see anything relative between geographical features of surrounding areas and the proposed development. Mrs. Dodder stated that Mr. Richter stated that the area was zoned Industrial, and she was saying that there was no change of zoning. Mr. Gibbons stated that through new postings there is a plan for more single family units. He asked Mrs. Dodder if she felt that this will create a need for neighborhood services. Mrs. Dodder stated that she does not feel that there will be such a need. Mr. Stewart asked Mrs. Dodder if she feels that the proposed area would be possible for a residential development. Mrs. Dodder referred to Planning Commission decision of March, 1973, stating recommendation for approval if Restricted Commercial One was substituted for Commercial One and leaving the Residential One-A. Mrs. Dodder stated that Mr. Richter made the comment that there wasn't enough room available in the commercial area across the street. S~e stated that she spoke to Mr. Becker and he said that there is quite a bit of room available. She stated that Mr. Richter's development will detract from the commercial area across the street. Mrs. Dodder stated that when they bought their home they were promised that the area surrounding them would be single family residential. Mr. Gibbons asked when Mrs. Dodder purchased their home. Mrs. Dodder stated that it was in 1966. Mr. Gibbons asked if at that time, the interstate was complete. Mrs. Dodder stated that it was not completed, but that it was designated on the plan. ~-' -3- Alan Demuth, attorney, stated that there could be a need for some commercial services in the area, but it should be a Restricted Commercial nature. There is no Industrial areas surrounding Mr. Richter's property. He stated that Coors has a permit to mine the gravel, but there is no Industrial zone. Mr. De;nut'1 stated that the Planninij Commission will not be adding on to an existing commercial district, but will be .,creating a nBW one at an undesirable site. He stated that 1-70 is H natural'barrier betw88n the existing commercial district and the residential area. Mr. Demuth submitted recorded covenants for Applewood Gardens, which stated that this area is intended to be single family residential. Mr. Demuth stated that the Commission is being contradictory to their decision of last year. Mr. Demuth stated that if the Planning Commission approves the outline development plan, they are allowing Mr. Richter to breach contractural rights of the people living under the covenants of Applewood Gardens. He stated that one of the things absent in Mr. Richter's presentation is an adequate demonstration of the need for commercial property. Mr. Demuth stated that if there was an adequate demonstI'ation, Mr. Richter would have filed a preliminary development plan at the time he submitted the outline development plan so they would have a better idea as to what he proposes. Dr. Bebber asked Mr. Demuth if he considers Applewood Shopping Center a good center. Mr. Demuth stated that he feels that it is an Lnder c8veloped C~~~3~. He stated that it has its good qualities and its bad qualities. Mr. Demuth stated that if they go with Planned Commercial Development, it would be contrary to what he thinks the City would want to stand for, and that is to encourage people to meet contractural agreements. Mr. Gibbons asked what Mr. Demuth thought about the gravel mInlng in the area directly northwest of the residential area. Mr. Demuth stated that if they had had the opportunity to do something about the mining they might have, but the Planned Development is for lakes in the area. The gravel trucks will not always be there. Mr. Jenks asked how the proposed zoning violates the covenants. Mr. Demuth stated that they are intended to create single family residence and not a commercial area. Mr. Wigert stated that if the Planned Commercial Development is approved, it will replat the covenants. Mr. Richter submitted newspaper clippings from October 17, 1973 issue of the Denver Post stating, "the Adolph Coors Company last week completed the final part of its Industrial rezoning of Clear Creek Valley." Mr. Richter stated that he did go to Jefferson County Courthouse in an attempt to get a copy of the current map. The map has not been updated since the time the zoning was approved. He stated that the map however, is in place and it does show Industrial-Two Planned Development. He stated that the implication is that there will be lakes there, but it is Planned Industrial-Two. Mr. Richter stated that he has three legal opinions stating that the covenants do not prohibit commercial development, and no where is it inclusive that that is a residential area. Mr. Richter stated that there has been problems in the transfers and recording of some of the covenants, but even if they are applicable the buildings can be built in a different location on the site. Mr. Richter stated that he fails to see how a highway like 1-70 can be a natural barrier. He stated that the outline development plan was not meant to be evasive. It is one that is within the ordinance, and one that the Planning Commission can approve. MOTION by Dr. Bebber, second by Mr. Jenks, "Case No. WZ-74-18, northwest intersectio of 1-70 and West 32nd Avenue be forwarded to Council for approval in that it is a material upgrading of the area, and is good usage. We will look forward to the Preliminary Plan, at which time we will layout definite development plan as we established. On the basis that the deletions and amendments that were restated tonight be sent to City Council." Motion passed 5-0. -4- Mr. Wige"t stated that Case No. DP-7402, which was to have a decision made tonight, be tabled indefinitely. MOTION by Mr. Lewman, second by Dr. Bebber, "Move that dumping permit on 4801 Tabor Street be tabled indefinitely." Motion passed 5-0 '. DEEDS AND SPECIAL PERMITS Speci~l permit fo" Lane Engineering for B proposed sanitary sewer line extension within Westridge Sanitation District. Mr. Emmet Land presenteu case stating that Mr. Alvin Alberts bought the property from Mr. Lockhart. Mr. Alvin had to pay a application fee of $3,000 to Westridge Sanitation for the application to put sewer line in. At the time he filed for the application, he gave West ridge permission to install the line. MOTION by Dr. Bebber, second by Mr. Lewman, "The permit be given subject to easement." Motion passed 5-0. There being no further business, the meeting was adjourned at 8:15 P.M. Respectfully Submitted, (I, i/" t" . \,... 1..- , \. '- ~ - I l /, \ cr~ ,', Greene, Secretary Connie CIr1 COUNCIL HEARllJG DATE: August 29, 1974 , r".....~\J wJ..J. CERTIFICATION OF RESOLUTION ~, WHEAT RIDGE PLANNING COMMISSION (To City Council) I, Connie Green2 , Secretary tJ the City of Wheat Ridge Planning Commission, do hereby and her2~ith certify that the following resolution was duly adopted by 5-0 vote of the members present at their Rppri 81 public meeting, held in the City Hall, Wheat Ridge, Colorado, on the 26th day of August , 19~, and the roll having been called, the vote of the Commission was as follows: Stewart Aye Bebber Aye Lewman Aye Jenks Aye Harlbw Aye Case Number; WZ-74-18 Applicant1s name: Dwaine Richter Location; Northwest of intersection of 1-70 and West 32nd Avenue From Present Zoning of; To Proposed; Planned Commercial Development Purpose; Area: Acres = 10 Square Feet = WHEREAS, the City of Wheat Ridge Planning Department has submitted a list of factors to be considered with the above noted rezoning application, and said list of factors is attached hereto and incorporated herein by reference and made a part hereof; and MOTION by Dr. Bebber, second by Mr. Jenks, "Case No. WZ-74-18, northwest intersectio of 1-70 and West 32nd Avenue be forwarded to Council for approval in that it is a material upgrading of the area, and is good usage. We will look forward to the Preliminary Plan, at which time we will layout definite development plan as we established. On the basis that the deletions and amendments that were restated tonight be sent to City Council." c,,; TL~ ~iJ::i.5 Lath dol} of AIIQIIst '0 _. ~ .1. J --'..f:i.-. (I {;11. i~ f'{' (/ \ (I Q VlO Connie Gre!!e, Secretarl} to the City of Wheat Ridge Planning Commission ltl.R. Form 5-34 CIrv COUNCIL HEAR~JG DATE: August B, 1974 CERTIFICATION OF RE5oLUTION CITY OF WHEAT RIDGE PLANNING COMMISSION (To City Council) I, do by public day of of the Connie Greene ,Secretary t8 the City of Wheat Ridge Planning Commission, hereby and herewith certify that the following r8solution was duly adopted 5-0 vote of the members present at their regular meeting, held in the City Hall, Wheat Ridge, Colorado, on the 5th August , 19~, and the roll having been called~ the vote Commission was as follows: Stewart Aye Bebber Aye Harlow Aye Scoma Aye Lewman Aye Case Number: WZ-74-18 Applicant1s name: Dwaine Richter Location: Northwest of intersection at 1-70 and West 32nd Avenue From Present Zoning of: To Proposed: Planned Commercial Development Purpose: Commercial Development - Outline Development Plan Area: Acres == 10 Square Feet == WHEREAS, the City of Wheat Ridge Planning Department has submitted a list of factors to be considered with the above noted rezoning application, and said list of factors is attached hereto and incorporated herein by reference and made a part hereof; and MOTION by Dr. Bebber, second by Mrs. Scoma, "r move that the Preliminary Outline Development Plan, Case No. WZ-74-18, be accepted and forwarded to Council with the deletions as accepted by the developer from the group that he has submitted. r feel that it is an upgrade of this plece of land, and is good for the community." r..,,-rr"" .1..!-~_ ....\i _-" _.1_-' 6t~ day of AUGust . ],9'7& < (7nf1 N: '(; O,},?p He Connie GTe~e, Secretarv to the City of Wheat Ridge Planning Commission II R. F'lTm 6-34 \v {~! ar;.:~ (r ( M E M 0 3 April 1974 TO CITY ADMINISTRATOR FROM PLANNING DEPARTMENT SUBJECT RICHTER PETITION FOR ANNEXATION Planning Department has reviewed the petition for annexation submitted by MI'. Dwaine Richter on 19 March 1974, and hereby makes the following Finding of Fact: 1. The boundary of the proposed annexation that is contiguous with the City of Wheat Ridge, exceeds the 1/6th requirement as per 139-2~-3(2) of the Colorado Revised Statutes. 2. It has been determined by the Engineering Department that the legal description of the proposal is valid and accept- able. (See attached memo from the Chief of Engineering) The Planning Department makes the fallowing comments and recommendations: 1. The Jefferson County Future Land Use Plan prepared in 1961, and adapted by the City of Wheat Ridge, recommends low density residential uses (0-4 dwelling units/acre) far the general area in question. The Land Use Plan prepared and adopted by the City of Wheat Ridge in September, 1971 do not extend beyond its present corporate limits therefore, not inclusive of the parcel in question. However, it does recommend commercial uses immediately to the east, adjacent to the proposal. ....- /' 2. The Planning Department recommends that within 90 days of the effective annexation, the petitioner make application for zoning under Section Twenty of Ordinance 98 "Planned Commercial Development District". This method of zoning and development will provide for proper site development including: (a) Approval of uses; (b) Controlled access; (c) Interior vehicular and pedestrian circulation design; '(d) Desirable sign graphics; (e) Landscape design; (f) Building design providing proper architectural continuity throughout the development. This concept will offer the amenities and uses that will be an asset to the area. 3. The Planning Department feels that this location is a potential commercial area and would be the most appropriate and reu~unable use of the parcel. GWG/cs ~ INTERDEPARTMENTAL MEMORANDUM APRIL 1, 1974 TO FROM SUBJECT GARTH GIBBONS, PLANNING TECHNICIAN CHIEF OF ENGINEERING PROPOSED ANNEXATION BY MR. DWAINE RICHTER In reviewing the attached legal description and plat of the proposed annexation, I find the description and plat ~o be adequate and correct within tolerable limits. However, in reviewing the proposed annexation, we found that there is a bust in the current legal description of the Ci ty limits. The City legal description states a distance of 357.0' W. from the North West corner of the NE Quarter, SW Quarter of Section 29 to the West Right-of-Way line of 1-70 being the Western City boundry at this point. The plat submitted by Mr. Richter shows this distance to be 456.57' which I believe is correct. ( I \ 1.-;"" It appears to me that the legal description of the City limits should by reviewed by a registered land surveyor to correct this error and any other error which may be present. ~~/,,""/" / A.-' 77~~-~"-,, --- '..../-- LARRY R .,"':tROMAS LT.... LRT/lt Attachment cc: Walter Rubkowski, Director of Planning WHEAT RIDGE PLANNING DEPARTHENT CDr'U"1ENTS CASE NO: WZ-74-18 Name Dwaine R. Richter Address 2860 Berry Lane, Golden, Colorado Location Northwest of intersectio~ at 1-70 and West 32nd Avenue Zoning Amendment Requested Planned Commercial Development Purpose: Commercial Development Approximate Area: Acres = 10 Square Feet = Contiguous zoning is: Contiguous land use is: East 1-70 West Unincorporated North Unincorporated South Unincorporated East Commercial West Residential General area land use is: North Vacant South Residential East West North South East West North South General area zoning is: The following factors should be considered in the overall perspective of the request for zoning amendment: 1. The parcel is not in the designated Flood Plain. 2. The parcel is presently vacant. The Planning Department makes the following comments and recommendations: 1. The applicant has submitted an outline development plan. A decision must be rendered concerning rezoning to PCD. Intensive scruting of the plan should occur at the Preliminary Development phase. 2. The State Geologist has concluded the parcel has no commercially valuable mineral deposits. 3. The proposed uses described in the developer's statement are generally consistent with Commercial-One zoning. One exception is the indoor warehousing, a Commercial-Two use. 4. An irrigation ditch traversing the property will be relocated to follow along the west property line. This area will be planted, and with the surplus water, dense vegetation will grow providing a buffer effect for the residential area to the west. 5. Several design alternatives have been discussed with the developer. Depending upon uses approved, the appropriate overall design will be incorporated in the Preliminary Plan. 6. The Planning Department recommends that the Outline Development Plan be approved for the following reasons: 1. The Land Use Plan does not cover this area. The Planning Department recommends the parcel be zoned commercial because of its proximity to 1-70. ~ 2. Planned Commercial Development will insure optimum uses and design. [ ~' TI T J <;Tq[(T ;f.'. ! ,. \, , I ','I : I ,I -<' -, G) l> :0 o !TI Z en " I . 'o~_:C~ ~--~-'::~~-'-~-./:r~~~.~~' --~~-=~ :~1.n . ,:~C"':=--_:c:,:'C~'.__ - .. '--:I: 'I~lfl~}~!~~~~j~~~c~: --- .-='-- --. -. ~ ;:c-._-~- ._..::_ __ ~. _:-::;: ~~ LAW OFFICES OF ROVIRA. DEMuTH 8. EIBERGER LUIS 0 ROVIRA WALLIS L. CAMPBELL LAEl.5 DEMUTH CARL F EIBERGER WilliAM G KEMP ALAN C DEMUTH ROBERT A. BACKUS ROBERT L. ROBERTS WilLIAM F SCHENKEIN DONALD A HOUlEHAN 1600 WESTERN FEDERAl- SAVINGS BUILDING 718 SEVENTEENTH STREET J H SHEPHERD "F COUNSEL DENVER, COLORADO 80202 TELEPHONE 303- 222 -1808 RUSSELL P ROWE J WALTER HYER III EDMUNDO A. GONZALES CHARLE::; A. HILLESTAD DANIEL C LYNCH RICHARD M LAVERS LORING I::: HARKNESS JEFFREY G PEARSON DOU GLA~ 0 POOTE January 24, 1975 William E. HcCarthy, Esq. City Attorney The City of Wheat Ridge 3760 Vance Street Wheat Ridge, Colorado 80033 Re: Mary C. Dodder, et al. v. ~l:.:h.~ ~ .:i'i~i:i}J-_eil_,_13r~~g_ham.. ~_~_ a 1 . Dear Bill: Enclosed is a fully executed copy of the Stipulation for an enlargement of time. As you had already signed it, we took the liberty of forwarding the original to the Court for filing. I wish to thank you for making it clear in the Stipulation that an Answer will be filed. This clarifies our earlier telephone conversation wherein I indicated the Plaintiffs consent to the enlargement of time would be viewed more favorably, if an Answer was filed and not a Rule 12(b) Motion. Your courtesy in preparing the Stipulation is much appreciated. I apologize for the delay in returning the executed Stipulation to you; however, I have been out of the office for the last week at an extended trial. Very truly yours, ROVIRA, DEMUTH & EIBERGER CLL~LL7~~ Alan C. DeMuth\' ACD Ikc Enclosure LAW OFFICES 0'" ROVIRA. DEMuTH a EIBERGER LUIS D ROVIRA WALLIS L, CAMPBELL LAEL S. DEMU1"H CARL F EIBERGER WILLIAM G, KEMP ALAN C. DEM UTH ROBERT A. BACKUS ROBERT L. ROBERTS WILLIAM F SCHENKE1N DONALD A. HOULEHAN .800 WE:STERN IfEOERAL SAVINGS BUILDING 7'. SEVENTEEH'fH STREET j H. SHEPHERD OF COUNSEL DENVER, COL.ORADO 80202 TELEPHONE 303- 222 -Ieoe January 24, 1975 RUSSEL.L P ROWE J WAL. TER HYER It I EDMUNDO A. GONZALES CHARLES A. HILLESTAD DANIEL C LYNCH RICHARD M LAVERS LORING E. HARKNESS JEFFREY G PEARSON DOUGLAS 0 FOOTE Clerk of the District Court County of Jefferson 1701 Arapahoe Golden, Colorado Re: Dodder, et al. v. Brougham, et al. Civil Action No. 46041, Div. 3 Dear Sir: Enclosed herewith is the original and one copy of a Stipulation for an enlargement of time along with the original Order in connection with the above-referenced action. If the Stipulation appears satisfactory, kindly have the Court execute the Order. In addition, please return a time-stamped copy of the Stipulation to the undersigned in the enclosed, self-addressed envelope. Thank you for your prompt attention to this matter. Very truly yours, ROVIRA, DeMUTH & EIBERGER (]lL8{LW,( ~ Alan C. DeMuthC ACD/dh Enclosures cc: William E. McCarthy, Esq. IN THE DISTRICT COURT IN AND FOR THE COUNTY OF JEFFERSON M~D STATE O~ COLORADO Civil Acti..on No. 46041 Div. 3 Defendants. ) ) ) ) ) ) ) ) ) STIPULZ\TION ~''Ln.RY C. DODDER, et al., Plaintiffs, v. ELISE HcHILLEN BROUGHlIl1, et al. f cmres Nml, Nilliam E. t1cCarthy, Attorney for Defendants, and Alan C. De!1uth and J. vIal ter Hyer, III, Attorneys for Plaintiffs, and stipulate as fo110\15: The above defendants may be allowed an enlarge- ment of a period of time in 'ilhich they are required to anSiver service of Summons and Complaint. co from plaintiffs' Complaint to an additional vHLLIAl'1 E. Hc THY Attorney for Defen Post Office Box 6 0 ~fueat Ridge, Colorado 80033 Tel~~:'~Q . ALfu~ C. DeHUTH .. Attorney for Plaintif s 718 17th Street, Suite 1600 Denver, Colorado 80202 ;/i ~I .:v.' HALTER I ~E., IIIJ Aktorney for Plaintiffs 718 17th Street, Suite 1600 Denver, Colorado 80202 IN T:-J:E DISTRICT COUR'l' IN AND For, THE COill1TY OF JEFFERSON M1D STATE OF COLOR.i\DO Civil Action No. 46041 Div. '1 De fendan ts . ) ) ) ) ) ) ) ) ) OROBe< ~t.i\RY C. DODDE'R., et al" Plaintiffs, v. ELISE 11dlILLE~1 BROUG'{;\H, et aI., Defendants are granted an additional t\venty (20) days from service of SUffi!T\ons and Complaint in 'tlhich to anslver. DONE THIS DAY OF A.D. 1975. B'1 THE COURT: lJUDGE .~ ,No. 195CA. Re.... '73 8UMMON81N CIVIL AC'ri~N',--Bmtord PubU.hI.c1::.... t824'~6 Sto..t St...... Donv.r, Color.do 1~n-.QIl)-l\looH ~------~ _.__.--- .- .:":1 COUIe Filing Stamp --- DISTRIcr IN TIIE........,.., ,. ..............._..COURT IN i'\NO FOR ..,......m.,._...COUNTY OF....,~~~~,..,......__ AND STAT}: OF COLORlI,DO Civil Action No............,................._ Div...........m... MARY C. OOODER, FRANK FFAUENFELDER, ARI'HUR F. BRU:n'Ol1, GARY H. HOLBFroK, JEIDNE W. BOE'ITCHER, NADINE J. BOETI'CHER, llARRY NILLIAMS, T.TIJ.TAN' IRENE WILLIAMS, in behalf of them- selves and all. 9ttters similarly situated Plaintiff..S..._.. SUMMONS c -. ..., l> -1 o ::0 ~ -, <) I~~'-l -I ...- .< ~ ,-- --, 0 ;:D l-! L...; :0 _fTJ I / , J~1 -10 - .:J . J G. i:) U ;, ('":' '\ ELISE McMII.U:N BRI5tGm\M, City Clerk of the City of t'1heat Ridge, State of Colorado i THE CITY OF WHEAT RIDGE, a municipal corporation of the State of Colorado, DR. PAUL B. ABRN-1SON, and HGr-1E L. ROES:ENER, as Mayors of 1 the City of Wheat pidge; IARRY G. MERKIE, Defendant..!?___. JOSEPH M. OONALDSCN, FOBERT G. HaVARD, au; O. HUlSEY, !DUISE F. TURNER and MA..-q'{ JO CAVARFA, Alderrren of the Citv of t'lheat Ridge THE PEOPLE OF THE STATE OF COLORADO TO THE ABOVE NAMED DEFENDANT-.s--__, 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 you. Warning: If this summons does not contain the docket number of the civil action, then the complaint may not now be on file with the clerk of the court. The complaint must be filed within ten days after the summons is served, or the action may be dismissed without notice upon your proper request to the court. Information from the court concerning this civil action may not be available until ten days after the summons is served. ',,- "\- This is an action* for declaratory and injunctive :relief as rrore fully set forth in the Carrplaint attached hereto. January 13, 75 Dated..''.....'....,__...'..' ..."..,......,....",,' ..__..".., 19..,..,.___.. ....... .... ................. ...... ...... ........_.._.__.._.................._.........~.n....._...... Clerk of. said Court .:;:;!1l'li:?~J'(............ r;~ /t;lfft'plai' By "'..".,......."._'..m._.._.._______.__.,.._..".....'......-. Deputy Clerk .~i~~1~~TId~~t1t~~;;'~f~'.)?~~9.:.. Denver, Colorado 80202 Telephone: [303] 222-1606 (Seal of Court) .-nIl IUIIl",0111 t. baued punu...t to Rut. 4. C.R-C.P.. U &mddecl. U the aum.mO'U .. l)abUalt.ed or .oft"p~ .{thout. . ~ of the eoIIIplaJat. a1t.r the 'Word .'&C.t.lon" at.at.e the re~le( deft\&..... u: ~ eseeuUOQ '- .,u.ht. the RlDftlOIl. 1JlU.' .\.a.... o-rb.1a ~ &II. actlOIl fouadcd Upoll wrt.u ,"0$ , ...L ,.is.. , .oiiW!D\ " ,) IN THE DISTRICT COURT IN AND FOR THE COUNTY OF JE~FERSON STATE OF COLORADO Civil Action No. _~___ Div. MARY C. DODDER, FRANK FRAUENFELDER } ARTHUR F. BRUNTON, GARY H. HOL-- } BROOK, JEROME W. BOETTCHER, ) NADINE J. BOETTCHER, HARRY ) WILLIAMS, LILLIAN IRENE WILLIAMS, ) in behCilf of themselves and all ~ other!'> similarly sit.u"ted, ~ [ ) ) ) } ) ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff~r vs. ELISE McMILLEN BROUGH~I, City Clerk of the City of Wheat Ridge, State of Colorado; THE CITY OF WHEAT RIDGE, a municipal cor- poration of the Stat:e of Colorado, DR. PAUl, B. ABRAMSON, and HOMER L. ROESENER, as Mayors of the City of Wheat Ridge; LARRY G. MERKL, JOSEPH M. DONALDSON, ROBERT G. HOWARD, CALVIN O. HULSEY, LOUISE F. TURNER and MARY JO CAVARRA, Aldermen of the City of Wheat Ridge, Defendants. COMPLAIN'!' Plaintiffs, by and through their attorneys, Rovira, DeMuth & Eiberger, and Alan C. DeMuth and J. Walter flyer III, allege for their Complaint the following~ FIRST CLAIM FOR RELIEI:' ~~"-".~-',- I-I. Plaintiffs Mary C. Dodder, Frank Frauenfelder, Arthur F, Brunton, Gary H. Holbrook, are citizens and residents of the State of Colorado and tlf the County of Jefferson, and are the duly appointed representatives of the peti.tioners of the referendum petition as more fully set forth infra. 1-2. Plaintiffs Jerome W. Boettcher, ~'adine J. Boettcher, Harry Williams and Lillian Irexw \'7illiams, are citizens, residents and qualified electors of the State of Colorado, County of Jefferson and the City of Wheat Ridge, and were signers and/or circulators of the referendum petition as more fully set forth, infra. 1-3. Plaintiffs bring this action on behalf of themselves and as representatives of the class of all citizens and residents of the City of Wheat Ridge, who signed referendum petitions challenging the validity of municipal legislation designated as Rezoning Case WZ-74-18 enacted 1...... .L'!..._ ....._z:__..:I__~ ~.: .J...... _.1: ...'11..__...... ft.J ~__ " c".Jt&! .' 1-4. Defendant Elise McMillen Brougham, is, and was at all times herein mentioned, the duly qualified and acting Clerk of the City of Wheat Ridge. 1-5. Defendant City of ~lheat Ridge, is, and was at all times herein mentioned, a statutory municipal corporation organized and existing under and by virtue of the laws and the Constitution of the State of Colorado. 1-6. Defendants Dr. Paul B. Abri:!mson, succeed.ed by Homer L. Roes{^nex, Larry G. Merkl, Joseph M. Donaldson, Hobert G. Howard, Calvin O. Hulsey, Louise F. Turner, and Mary Jo Cavarra, are the duly elected mayors and aldermen respectively of the City of Wheat Ridge. 1-7. The class herein consists of 1108 (1808) qualified electors of the City of Wheat Ridge, County of Jefferson and State of Colorado who signed referendum petitions as more fully set forth infra; as such the class is so numerous that joinder of all members is impracticable. 1-8. There are questions of law or fact common to the class. 1-9. The claims of the Plaintiffs herein are typical of the claims of the class of petitioners they represent. 1-10. The representative parties Plaintiff herein will fairly and adequately protect the interests of the class. 1-11. The Defendants opposing the class have acted or refused to act on grounds generally applicable to the class, thereby making appropriate final injunctive relief or corresponding declaratory relief with respect to the class as a whole. 1-12. Pursuant to C.R.S. S 31-23-204 (1973), the City of Wheat Ridge adopted by duly enacted ordinance on March 2, 1972, a comprehensive zoning ordinance for the City of Wheat Ridge. 1-13. On August 29, 1974, pursuant to C.R.S. 31-8-109 (1973) a notice of protest was filed with the Aldermen and Mayor of the City at Wheat Ridge objecting to the zoning of a 10 acre tract of land for "planned commercial development" in Rezoning Case WZ-74-18, herein- after referred to as the Richter property at I-70 and W. 32nd Avenue. -2- :...;)" 1-14. On August. 29, 1974, pursuant. tel C.l"S. ~ :n-8~115 (1973), the Aldf>rman and Mayor of the City of Wheat Ridge exercised a legislative function by unanimously Cl.dopting a "motion" l~ather than an ordina1')('e or resolution within the 90 day statutory period fOT annexed land; the efff!ct of such enactnH?Ylt, \\'o~; te> ,.mend the Zoning (l'r(1:i nance of the Cit.y of Whcat. Ridge' t(", :ume 1 h(' 1 (J 21.('1 (' t'rac't fOT "planned ccmunercial developm.;;;nt". (Rezoning case W7.--'/!j'.18), 1-15.. Pursuant to C.R.S. ~ 1"40-115 (197:1) and (',R.S. S 1, ItO.lOG (1973), referendum pet.it.ions were duly circulat.ed itlTlong the qualified l"Ject:oIs of the Ci't-y of Whe...t Ridqe chaLlenging thf> zc)))inq legis1aticm adopt.ed in WZ- 74,-18. 1-16, l'ursuant, to C.fLf:. S 1-40"11'1 (Jqrn n;f(''f(~ndul1l pelH,iems bearin~r the, 1808 sig'f!<'l.tu.res which is in excef,,; of ) !,% pi the total vote (459S voted) for. all candidateft fol' m.CiYc))- e:of;t in the last. pre.cec3:iIJ9 election of mayor were filed on September 27 and Sr:pt,ember 301 19? 41 wit,h Elise McMillen Broughi'.uJ'l, Clerk of the City of. V~hE'a.t Ridge. 1-17 < On October 3, 1974, Elise Mdhl1cn nrougbarll., Clerk of the City of Wheat Ridge, exceed.ed her authority and act:ed \.mlawfully in refusing to accept the petitions and in refusing t.o forward the petitions to the municipal legislative body for approval, ill violation of C.R<S. 51'"40-115 (1973) and C.R.So ~S 1~40-1Hi (1973), and l\rticle V, Section 1, Constitution of Colorado. 1-18. On October 10, 1974, t:he referendum petit"ions were presented to the Aldermen and Mayor of the City of Wheat Ridge who adopted < Rest':.lution No, 34 (; refusing the p('tit~iQn1';, 1~19< Resolution 346, adopted after t.he circulation and presentaticllJ of petit.icms, purports t,Q impose additional ].-equi.rel1lElots for: the lawfuJ exercise of the right of referendum, such requirements imposing a burden upon peti tioners in excess of the constitutional cHld statutory pro- cedure: dS such the passage and content of Resolution 346 are unlawful, violat:ive of Article V, Section I, Co10rado Constitution, in that the same impa,irs the petitioners' right of referendum. -3~ 1-20. The referendum petitions were signed by qualified electors and were circulated in compliance with C,R.S. S 1-40-106 )1973). 1-21. The legislative act sought to be reconsidered by the petitioners consisted of an amendment to the zoning ordinance for the City of Wheat Ridge, and as such, is a proper matter for referencum pursuant to C.R.S. S 1-40-115 (1973). 1-22. The municipal ordinances of the City of Wheat Ridge, insofar as they refer to referendum petitions, do not contain criteria for the manner of exercise or for the conduct of municipal. referenda within the City of Wheat Ridge. 1-23. The Defendants' refusal to accept the :referendum petitions and their passage of Resolution 346, were, therefore, an arbitrary, capricious denial and' unlawful exercise of municipal authority in excess of their jurisdiction, and constitute a violation of Article V, Section J of the Constitution of Colorado and impair the r:iqht of referendum as reserved to the class of petitioners of said constitutional provis)o)) and by C.R.S. S 1-40-115 (1973); further, said Defendants had no authority or discretion to refuse to accept said petitions or to refuse to either reconsider WZ-74-18 or call a referendum. 1-24. The petitioners and the members of the class whom they represent will suffer immeasurable and irreparable harm in that Defendants have effectively denied Plaintiffs and the members of the class they represent their constitutional and statutory referendum right by virtue of a purposeful, arbitrary, capricious and unlawful exercise of municipal authority. 1-25. There is a real and actual controversy between the parties. 1-26. Plaintiffs have no adequate remedy at law. WHEREFORE, Plaintiff's pray: 1. For the issuance of a writ of mandamus directing responding City of Wheat Ridge to: a. Rescind its action of October 10, 1974, wherein it denied to act upon the referendum petitions filed with the City Clerk on September 27 and September 30, 1974, and refused to either repeal the zoning "motion" or to submit the same to the voters; -4- -dr b. Suspend the effective date of the zoning "motion" until respondent City of \~heat Ridge repeals 'lhC'~H" ,;ection::> or ,.mU 1 the electors of the City of Wheat Ridge are affonlecl the right to referendum; 2. For a declaration that a municipal legislative act, properly the subject matter of ordinance or resolution, may not be enacted as a "motion" t.o impair the right of referendum or for any other purpOSE:; or, in the dlten,,,,t.ivE?, a mCltJ,OII 1S of the same effe(,t as CI. rcsoluUon fox referendun! purposes onder C.R.S. S 1-40~115 (1973); 3. For a dec~lar..t:ic.m th;,t the motion adopted Dnd enacted in \~i\' 74-18 is void, (;,nd of flO ~ffect fOl the r.eanc,n that j t vias in C;'XC€:Sf; of the )u:x:i.sdicti.of! and autho:tity of Defend"mU", cwd Uw'l. j t C0nst) 1 \lted a. arbitrary, "apricicms, and unlawful (''J.{:f~rc:isE' of T1i\lJdc,"ipa) authority; 4 < For a declaration that, the motion adopted and enacted in W7.-- 74-18, the action of Defendant City Clerk in refusing t:he petit.ions and the adoption of Resolution 346 were unconstitutional, void and of no effect for the reason that said municipal al:t:i ems Wf~:re 5n c(Jni;rc:.vcnU,ol1i of Article V, Section I, Colorado Constitution and C.R.S. !i 1-40-115 (1973 5. For a delcaration that, the substantive and procedural form of pet.itions were regularly, ,properly and lawfully prepared, as circulatec and presented to the Clerk of the City of Wheat Ridge ana to the Mayor andi Aldermen and that the Clerk and Mayor and Aldermen exceeded their authority and jurisdiction in refusing to accept said petition. 6. l'or a declaraticm that the state statutory criteria apply to govern the qualifications of signers and circulators of referendum petitions when a statutory city has no ordinance procedures for the conduct of a referendum: 7~ For an order enjoining Defendants herein from giving force and effect ,~nc1 consideration to WZ-74-18 and any actions regarding any development or conducting any hearing regarding the d~ve1opment of the Richter property at 1-70 and West 32nd Avenue, pending resolution of the issues raised herein. 8. For Plaintiffs' costs and attorneys' fees; 9. For such further relief as the court may deem just and proper, -5- t .f,: .~d$ ..' / SECOND CLAHi FOR RELIEF 2-1. Plaintiffs incorporate herein by reference the allegations contained in Plaintiffs' First Claim for Relief. 2-2. C.R.S. S 31-23-204 (1973) provides that the legislative body of a municipality may provide for the manner in which municipal zoning regulations shall be established, enforced, amen0ed, and repealed. Pursuant to that statutory authority, the city of Wheat Ridge adopted by duly enacted ordinance a comprehensive zoning ordinance for the City of Wheat Ridge on March 2, 1972. 2-3. C.R.S. S 139-60-4 (1973) contemplates that subsequent zoning determinations, amendments, supplements, changes, or repeals, shall, be, enacted with the same formality and with equal dignity as that manner and procedure by which the municipality first exercised the power to zone by municipal ordinance. The Defendants, however, purported to give effect to that zoning ordinance by enacting a "motion" on August 29, 1974, to zone the Richter property at 1-70 and West 32nd Avenue, for "planned commercial development." This subsequent procedure of zoning by "motion" lacks the same dignity and formality as the municipal zoning ordinance which it purports to implement. 2-3. C.R.S. S 31-12-301 to 31-12-309 (1973) permits municipalities in Colorado to impose local penal sanctions only by ordinance. Failure to act by ordinance in imposing local penal sanctions deprives citizens of adequate notice and denies to local citizens due process of law as guaranteed by the fourteenth amendment of the U.S. Constitution and Article II, section 25, of the Colorado Constitution. 2-4. Section 32 of the Zoning Ordinance of the City of Wheat Ridge imposes criminal penalties for violation of the zoning ordinance; but subsequent zoning actions whether by way of rezoning, amendment, or repeal enacted by "motion" and not by ordinance need not and are not published to ?,fford citizens of Wheat Ridge notice of proscribed conduct. The imposition of penal sanctions by a.procedure of less dignity than by ordinance not only violates C.R.S. 31-12-301 to 31-12-309 (1973) but also deprives the citizens of Wheat Ridge of the fundamental fairness guaranteed by the due process clauses of both the federal and state constitutions. -6- , J!lC '", WlJEREl"ORE, Plaintiffs pray: I, For a decla,ratiox, that sa10 zorLing jJ'J'oC:fdure by "motion" Jf; null and void in that a nmation" lackA the ctignity and formality to alter, amend, or implement an initial zoning ordinance; 2. For a declaration that said zoning pro~edure by "motion" is unconstitutional aT,d in cCll1traventic.>rJ uf state 'l,l\1 ill thi'lt the pnwechn ( subjectf< the ('iti:<"ens of Wheat Ridc:, iO 1'eni'11 SclllC tiOXlS without adfll\lat( notice in violation of Color.;l,do stiitut{->f~, federal and state canstj i \It )(,),S; 3. Par a permanent injwi~:t.i.('n ('njoin.in\~ 1)I,feodant Ci ty of Wheat Riclqe froll! enfo:r:cj,ng or i'i t. teniyting t.o c,n f"(J)'ce sc~id ,",orling II 1IJ()i. :i (Jj) i," , 4. For Plaintiffs' ~nBtH 01 buit herein; ~nd 5. Jo'or such further reJief C;'i the (OO\JT'\~ Illi;y (~('em jtlst. <,~nd proper, ReSl.>€'c:t.~ful1y !"ubmi tl.ed I ROVJ n7J)eM~'~\ ).::lllERGr~r rJY: ,., .L29, ':"~ ~~~-::tj~-:_u~ .y,.. J\l.~j)J;E:3}j(&~... J,rWal~er Hyer '&II ' J ~torneys for Plaintiffs 1600 vlestern Federal Say < Bldg, 718 Seventeenth Street Denver, Colorado 80202 (303) 2n~ 1606 I ACCEPTED THIS SUMMONS JANUARV 13, 1975 AT 4:10 PMc , R[C'[IVEO elT y "'''' <..~'... ("I T" ~) (' ;,~ ': i'\:fl ~~ J G;::: - ,1_ -, -:~ -J _~ .... ~ ELISE BROUGHA~ . , 17~)- ,IAN .1;3 PM 4; 35 .' l," !.; /, lJ:JJ : j ,~.. j-- {. ';:..- () i: -7- CITY CLERIC CITY TREA90 CtJUNCIC V MAYOR -" CI7Y ADM, .-/' CITY ATTY, ~ OEPT, HEADS' DISTRIBUTED ~ OAT~ lj;a/7~- 'j!iJ, -.JOHN -.J GIBBONS ATTORNEY AT LAW 255 CLAYTON STREET DENVER. COLORADO 80206 .~ .:::::> TELEPHONE 3i83 8-PJ~-/c:::..f ~ -' .. "">-- CALIFORNIA ADDRESS 1910 SUr-JSET BOULEVARC' SUITE 460 LOS ANGELES. CALIFORNIA 90026 1 ~LEPHONE 484-1870 0ctober 11, 1074 William E. \IcCarthy. )'sq. City Attorney City of Wheat Ridge Colorado 8003:) Re: Rezoning Case Wz-74-l8 Dear Bill; Just a short note to give you the following citations of Colorado cases on the question of "qualified" electors and one touching initiative and referendum. Benson v. The Election Commission of TJenver-- 6~ Colo. 206. (this is the case I talked with vou about that has "whishers" on it, decided in t11e September term in 1916) r. L. Frances et al v. Tean J. Pogers, City Clerk of the City of Lakewood, et aI, (this decis ion touches"base" on the question of referendum, how- ever, the subject matter is a special initiative and referendum ordinance passed by theCity of Lake- wood, although no such regulation' exists in the r:ity of Wheat qidge, this may prove of some merit to your contentions), This w~s decided September 21, 197:) and is reported in 514 P, 2d. 311. Colorado Project-Common Cause V. Byron A. ~nder- son, Secretary of State of the State of Colorado. !)ecided ~1arch 24,1972, renorted 495 p. 2d. 220. (interesting case on the question of "':,l"ilified" electors). . Sa~,tiago ll. Valdez, etal V. Flection Commission of Denyer, et al. (this is the latest enunciation of the Colorado Supreme Court on the "qualified," and "registered" elector). Decided Anril l, ] 974 and cited in 521 D. 2d. 165. Bill, again, 1 stand ready, willing and (1 hone??) to assist in any way to helD sustain your nosition the above caDtioned'matt~ "'~ '~, ,Tf)I"'rf' ]. r; I RRr)1\JS. 81'11e lJ1 ( DATE: 1~~Tt4- TO: )~ G\\-\-~ SU8~C~ I \ o?~ tt.l Cl\a ~ ~~. t \ WILLIAM E. McCARTHY , CITY ATTORNEY 1 nctober 1q7! Elise Brougham, ~lty Clerk Petition of Referendum, ~ezoninn Case WI-7G-18 I have acanned the subject petitions, reviewed the rity 'lerk's findings thereon, and have e' amined the lBw BDPlirable thereto. It is my determination that this netition effort falls short of ronstitutional/statutorv requirements. The Colorado Constitution. 1n Sertion 1 of Artirle V, amonqst other things, provides the followinq: "The initiative and referendum Dowers reserved tD the niople by this sertion are hereby further reserverl to the legal voters of every rlty, town and muniripallty as to all 10rsl, sperlal and munirinal legislstlon of every -hsTarter in or for their respective municipalities". In errordan, e with this constitutional orovislon, the state legislature has presrribed the manner for e.ercising the nower of referendum. C.R.S. 1953, 7n-1-15. It is thpre nrovided that this power may be exercised as to ordinanres, resolutions or franchises. And, 7r-1-9 provides that each oetition rontain an affidavit of 8 qualified elector. Statutory I"ities have the authority to provide for the manner in which zonina regulations and restrictions and the boundaries of zonin9 districts shall be determined, established and amended, supplemented or changed. 13g-~r-~. Applying the above references in reverse order, it is to be remarked that since its incer,tion, this city has accomplished its rezoning by motion rather than by ordinance, and it did so in this instance. It is therefore evident that the Dower of referendum is not available here since there is no ordinance, resolution or franchise to protest. Last but not least, it is to be noted that the constitutional and legisletive requirements as to qualified elertors applies not only to those signing the netition, but to those circulating the same (affiant). Therefore, the fourty-seven petitions (containing 1721 Signatures) circulated by other than qualified electors of Wheat Ridge are on their face invalid. Elise 8rou~ham, City Clerk 1 October 1971, Page Two Consequently, the remaining "valid" petitions carryinq but eighty-seven signatures do not rresent the reouired oercentage. I have attached a draft of 2 resolution implementinq this ooinion. WILLIAM E. McCARTHV City f1ttorney WEM/kkw ~. John A. Jerman, City Pdministratnr Attachment Introduced by Alderman RESOLUTION NO. Series of 19'7" WHEREAS, this body, on I\ugust Y-, 1'171" unanimously (G-n) adopted n motion approvinc rezonino in Rezoninc C~se WZ-74-18; and WHEREAS, 8 pretest has been rereived rEPresenting 18GB signatories contsined unon fifty-one (~1) petitions; end WHEREAS, fourty-seven (47) of these ~etitionG, containing 1721 signntures, were rirr.ulatec by nersons other than oualified ele'tors of the City of Wheat Ridre; Gn~ WHEREAS, the rezoninc action by this body was by motion rather than by ordinance or resolution; and WHEREAS, the power of referendum enn be eyer-leed only in protest of an ordinance, resolution or franchise. NOl~, THEfIEFORE, BE IT RESOLVED THAT the aforedeecribed petition effort is hereby declared to be invalid and of no effect. DONE AND RESOLVED this day of A.D. 1Q7', by e \late of to Homer L. Roesener, !"laljor ATTEST: Elise Brougham, Citlj Clerk DATE 1 October 1974 Elise Brougham, City Clerk Petition of Referendum, Rezoning Case WZ-74-13 TO SUBJECT I have scanned the subject petitions, reviewed the city clerk's findings thereon, and have examined the law applicable thereto. It is my determination that this petition effort falls short of constitutional/statutory requirements. The Colorado Constitution, in Section 1 of Article V, amongst other things, provides the following: "The initiative and referendum powers reserved to the people by this section are hereby further reserved to the legal voters of every city, town and municipality as to all local, special and municipal legislation of every character in or for their respective municipalities". In accordance with this constitutional provlslon, the state legislature has prescribed the manner for exercising the power of referendum. C.R.S. 1963, 70-1-15. It is there provided that this power may be exercised as to ordinances, resolutions or franchises. And, 70-1-9 provides that each petition contain an affidavit of a qualified elector. Statutory cities have the authority to provide for the manner in which zoning regulations and restrictions and the boundaries of zoning districts shall be determined, established and amended, supplemented or changed. 139-60-4. Applying the above references in reverse order, it is to be remarked that since its inception, this city has accomplished its rezoning by motion rather than by ordinance, and it did so in this instance. It is therefore evident that the power of referendum is not available here since there is no ordinance, resolution or franchise to protest. Last but not least, it is to be noted that the constitutional and legislative requirements as to qualified electors applies not only to those signing the petition, but to those circulating the same (affiant). Therefore, the fourty-seven petitions (containing 1721 signatures) circulated by other than qualified electors of Wheat Ridge are on their face invalid. Elise Brougham, City Clerk 1 October 1974 Page Two remalnlng "valid" petitions carrying but n present the required percentage. esolution implementing this opinion. ~-------~ WILLIAM E. McCARTHY City Attorney WEM/kkw cc: John A.;td~man, City Administrator Attachmen Introduced by Alderman RESOLUTION NO. Series of 1974 WHEREAS, this body, on August 30, 1974, unanimously (6-0) adopted a motion approving rezoning in Rezoning Case WZ-74-18; and WHEREAS, a protest has been received representing 1808 signatories contained upon fifty-one (51) petitions; and WHEREAS, fourty-seven (47) of these petitions, containing 1721 signatures, were circulated by persons other than qualified electors of the City of Wheat Ridge; and WHEREAS, the rezoning action by this body was by motion rather than by ordinance or resolution; and WHEREAS, the power of referendum can be exercised only in protest of an ordinance, resolution or franchise. NOW, THEREFORE, BE IT RESOLVED THAT the aforedescribed petition effort is hereby declared to be invalid and of no effect. DONE AND RESOLVED this day of A.D. 1974, by a vote of to Homer L. Roesener, Mayor ATTEST: Elise Brougham, City Clerk Int~oduc~d by Ald2~m3n RESOLUTION NO. Series of 1974 W~EREAS, this body, on August 30, 1974, unanimously (5-0) adopted a motion approving rezoning in Rezoning Case WZ-74-18; and WHEREAS, a protest has been received representing 1508 signatories contained upon fifty-one (51) petitions; and WHEREAS, fourty-seven (47) of these petitions, containing 1721 signatures, were circulated by persons other than qualified electors of the City of Wheat Ridge, thereby failing to comply with constitutional and statutory requirements; and W~EREAS, the remaining eighty-seven (87) signatures on the four (4) petitions circulated by qualified electors of the City of Wheat Ridge fail to meet the statutory requirement for fifteen (15) per cent of the total vote cast in the City of Wheat Ridge at the last preceding election for all candidates for mayor; and WHEREAS, the rezoning action by this body was by motion rather than by ordinance or resolution; and WHEREAS, the power of referendum can be exercised only in protest of an ordinance, resolution or franchise. NOW, THEREFORE, BE IT RESOLVED THAT the aforedescribed petition effort is hereby declared to be invalid and of no effect. DONE AND RESOLVED this day of A.D. 1974, by a vote of to Homer L. Roesener, Mayor ATTEST: El1.se Brougham, City Clerk U;,\ It.: ,.t-. ~ TO: -Pi SU8JECT' ~~- .;t~ ~~ ~. , ~~\ WILLIAM E , CITY AT" McCARTHY TORNE'f Acril ~, 197~ Mr. Dwaine R. Richter 286n Berry lane Golden, :olorado Bn4rl Dear Mr. Richter: This is to confirm our conversation after last night's City Council meeting with reference to your annexation petition to the City of lDheat fiidge, which was approved by Council resolution. May I remind you that you have ninety days in whioh to present your C8se for the rezoninQ process (City Planning Commission and City Council Public Hearings). Otherwise, the City Council will handle this matter without your consent and in accordance with their decision. !f the Planning Department can be of any further help, please do not hesitate to callan us. Very truly yours, Walter T. Rybkowski Planning Director WTR/kkw cc; City A~min18trator City Council ~Dril In, 1974 Mr. Dwaine R. Richter 28Gn Derry Lane Golden, Colorado sn4n1 Dear Mr. Richter: Confirming our telephone conversation of last night, r l"ould like to reiterete once again that your application ror rezoning should not come for change of zoning until annexation of your property is completely finalized by the City Council and not before thirty days after the ordinance is finally adopted. Sincerely, Walter T. Rybkowski PlanninQ Director WTR/kkw M E M 0 3 April 1974 TO CITY ADMINISTRATOR FROM PLANNING DEPARTMENT SUBJECT RICHTER PETITION FOR ANNEXATION Planning Department has reviewed the petition for annexation submitted by Mr. Dwaine Richter on 19 March 1974, and hereby makes the following Finding of Fact: 1. The boundary of the proposed annexation that is contiguous with the City of Wheat Ridge, exceeds the 1/5th requirement as per 139-21-3(2) of the Colorado Revised Statutes. 2. It has been determined by the Engineering Department that the legal description of the proposal is valid and accept- able. (See attached memo from the Chief of Engineering) The Planning Department makes the following comments and recommendations: 1. The Jefferson County Future Land Use Plan prepared in 1951, and adopted by the City of Wheat Ridge, recommends low density residential uses (0-4 dwelling units/acre) for the general area in question. The Land Use Plan prepared and adopted by the City of Wheat Ridge in September, 1971 does not extend beyond its present corporate limits therefore, not inclusive of the parcel in question. However, it does recommend commercial uses immediately to the east, adjacent to the proposal. 2. The Planning Department recommends that within 90 days of the effective annexation, the petitioner make application for zoning under Section Twenty of Ordinance 98 "Planned Commercial Development District". This method of zoning and development will provide for proper site development including: (a) Approval of uses; (b) Controlled access; (c) Interior vehicular and pedestrian circulation design; (d) Desirable sign graphics; (e) Landscape design; (f) Building design providing proper architectural continuity throughout the development. This concept will offer the amenities and uses that will be an asset to the area. 3. The Planning Department feels that this location is a potential commercial area and would be the most appropriate and reasonable use of the parcel. GWG/cs INTERDEPARTMENTAL MEMORANDUM APRIL 1, 1974 TO FROM SUBJECT GARTH GIBBONS, PLANNING TECHNICIAN CHIEF OF ENGINEERING PROPOSED ANNEXATION BY MR. DWAINE RICHTER In reviewing the attached legal description and plat of the proposed annexation, I find the description and plat to be adequate and correct within tolerable limits. However, in reviewing the proposed annexation, we found that there is a bust in the current legal description of the City limits. The City legal description states a distance of 357.0' W. from the North West corner of the NE Quarter, SW Quarter of Section 29 to the West Right-of-Way line of 1-70 being the Western City boundry at this point. The plat submitted by Mr. Richter shows this distance to be 456.57' which I believe is correct. It appears to me that the legal description of the City limits should by reviewed by a registered land surveyor to correct this error and any other error which may be present. ~ (- LARRY R. THOMAS LRT/lt Attachment cc: Walter Rubkowski, Director of Planning M E M 0 March 20, 1974 TO: CITY CLERK FROM: City Attorney, William McCarthy SUBJECT: Richter Annexation Petition --- > I have reviewed the attached documents and have found them to be legally sufficient. The following matters should have your attention: 1. It should be determined that in fact not less than 1/6 of the perimeter of the area is contiguous (Planning or Public Works). 2. It should be determined that description of the land is accurate (Ibid). 3. I understand that Richter is sole (100%) owner of the land -- if so, Council, by ordinance, may proceed to annex without notice or hearing. 139 - 21 - 6,(~ ytJ (h). 4. Land must be brought under our zoning within 90 days of effective date of annexing ordinance. --). 139 - 21 - 14 (2). 5. Planning should review this entire package and make comment. 6. If it is determined to have notice and hearings you should use resolutions etc. in Annex file #3 as model. I will review them. No fee is charged for annexation. ~:::..- -~i~-~ ) -.-- _.. .../ William McCarthy cc: Mr. Jerman Dr. Abramson ,<-.--- -- -. .- I "-" -i ,- ---- ---,...,---~~--_._--~--~---_._-_. ---- LAW OFFICES BRUNO, BRUNO AND BRUNO <IV< c;\\ " \) \-<, I V "- ~'<V' SUITE: 1175 CAPITOL LIP-I:: Ce:NT;::Ff c. 'eTH A\ll!:HU=:' &. S)>4i:RM"~ STREET ASSOC,AoTCS H~ C. REE:O DENVER,COLORADO 80203 861-8397 f"RAM'" A~ aRUMO LOUl5 B. B~UNO DAVia .J. BRU..o February 19, 1974 Mr ~_ :Ma.rti.n P. Mi.1.1.er Attonley ~t Law 1901 West Littleton Boulevard Littleton, Colorado 80120 :Re: Dodder vo Richter Dear Mr. Mi.ller: After our lunch on Wednesday, February 13, 1974, I met with the Plaintiffs in connection with the above entitled matter and fully discussed with them our conversation in the hopes of arriving at a settle- ment herein. Generally speaking, the Plaintiffs will accept and actively support the uses permitted by R-Cl _ zoning as provided by Jefferson County, Colorado. ,-:- Further, they ~l1 accept a motel-restaurant complex on the subject property if the rezoning proposal proceeds through Jefferson County rather than the City of Wheat Ridge. The Plaintiffs have a basic distrust for the City and its elected representatives and are therefore willing to concede the uses of the motel if Mr. Richter is willing to proceed through JefferSon County rather than the City. It should be understood that while the use as permitted by R-Cl of the county regulations are acceptable, .' , ~ -- ,/~ they would wish to work out a detailed plan with ~k. Richter to locate such uses on the subject tract. Please let me hear from you at your earliest convenience. .- .,.--'~ - ..'''''~ ';"'r~.-- ".-.-.-,--- ~, .:1:.: : .L:;;_.._ +: ~ ~ LBB/tc. ., , --.:-".. t,:,," -:;I - ., 1 j,!~,~ l~ Findings by the City Clerk regarding petitions turned in on Rezoning Case WZ-74-18 which was approved by City Council at approximately 3:00 a.m. on August 30, 1974 (Said Council Meeting began on August 29, 1974) requesting by petition that "the City Council reconsider and repeal entirely said reso- lution, or alternatively, to submit the same to a referendum vote of the qualified electors of the City of Wheat Ridge, State of Colorado." 1. A spot check by myself of the signers of the petitions shows that they are residents of Wheat Ridge. 2. A total of 51 petitions were turned into the City Clerk's Office. Of these, 47 were circulated by non-residents of Wheat Ridge, and 4 were circulated by residents of Wheat Ridge. 3. There was a total of 1,721 signatures on the petitions passed by non-residents, and 87 signatures on the petitions passed by-residents. There was a total of 1,808 signatures. 4. According to C.R.S., 1963, as amended, 70-1-15 and 70-1-17 the number of signatures required is 15% of the votes cast for all candidates for mayor. 5. In the regular Municipal Election held on November 6, 1973 the total number of votes cast for all the candidates for Mayor was 4,595. Fifteen percent of that number is 689.25. 6. The rulings of the City Attorney are as follows..... 7. I therefore~ Elise Brougham, City Clerk of the City of Wheat Ridge declare the petitions to be INVALID based upon the recommen- dation of the City Attorney William E. McCarthy. Petitions Circulated by a Non-Resident of Wheat Ridge Petition Number Number of Siqnatures 1 14 2 50 3 49 4 48 5 50 6 2 7 50 8 31 9 50 10 35 12 25 13 35 14 18 15 49 16 48 17 2 18 .- 31 19 50 20 50 21 50 22 6 23 50 24 50 25 50 25 Lf9 27 34 28 27 29 1 30 50 31 50 n 32 49 33 49 34 3 35 49 36 36 37 50 Petitions Circulated by a Non-Resident of Wheat Ridge Peti tion Number Number of Siqnatures 3B 50 39 50 40 49 41 49 42 24 43 27 44 23 45 50 46 7 47 11 48 41 TOTAL 47 TOTAL 1,721 Petitions Circulated by a Resident of Wheat Ridge Petition Number Number of Siqnatures 11 49 50 51 50 3 8 26 TOTAL 4 TOTPL 87 * * * * * * * * * * * * * * * * * * * * * * GRAND TOTAL 51 GRAND TOTAL 1,80B "-' '" ... -< c }--' 0 t:D 8 0 -0 :l n ::D 0 -:J rr := 0 l-j OJ EO: 3 -' m i- 0 ~ ::l Cl G1 - ::0 J:> Z C1 -l CJ -l ;p r CJ -rl e:: :D ::0 C1 U1 H H H G'l ::0 :D J:> ;2 2 C1 C1 H -l 1-1 0 H -- -l ;p :D r Z 0 :D OJ U1 r<1 Z -l r<1 r r<1 c:::: CJ -I JT\ U1 II 11 it \I .l:" ~ (\.1 - ~ -.J .+:" \Jl ~ . -. \0 ~ ....:l CJ \Jl Cl' CtI ~ rI "- \ . ;--' <..: w 0 l-j \ . 0 :;:~\ G'l . ('] -0 C,) ::l [lJ :D <CJ to -0 \ u o Cl := ro l-j l-j ::l CJ 0- E: 3 I-" ::r L1 0- t-" a \ p & ::J <1" ro c:1 N N e:: LT\ (\.1 \.D -0 \.D (Jl -J t-:l :D c:1 ::0 t1 C1 I-'" :l 1-1 n ~ ~ +" .... -.J CJ OJ \Jl -.J (Jl N U1 ~ (Jl LT\ C .l:" \.,l OJ tr .+:" \.,l \.,l rl' 0 c+ III l-' I ..de:: >i J:> ...>. 1II ::0 \.-1 -.J LT\ n 0 ...>. .+:" CJ I-'" :l H n H c+ v.: \ N \ ...>. UI co \.C 0\ co .+:" + ~ ~ UI .+:" O:l \.,l ..,J O:l Cl"I - en c ~ Ul + CT \.,l Ul \.C rl' + CJ CJ a rl' i ! ~\ i t . , \ ~t::::::- , -,- I $-i:~~ , ro>"l n 0- I-'" VI 0\ ::J HI ..,J Cl"I N n H ..... O:l -J .... H 0\ N \ \Jl 0\ CJ -.J ..,J +" N -J g'\ -> rt\ ...>. \Jl N \.>I -.J CJ \Jl CJ +" ~\ I N N ~\ \.,.l \Jl +" I i\ ~ 0 H --I -< CJ -rl :;: E: ;p :;: -< r<1 0 :D ::0 -I n :0 ;p H 2 0 0 G1 1-1 P1 0 :D :;: -l C fTI 2 U1 H n H -0 Z :D 0 r c:::: r<1 r<1 ~ r" r<1 r<1 CJ ::0 -l H CI\ 0 -- 2- .... \.C :0 -J {"1. \.>I. tn c .. -l en ~/ ./ . - H E i"l 0 TQ: Jchn A. Jerman City Administrator FROM: City Attorney DATE: March 4, 1974 SUBJ: Changes/Amendments to Zoning Ordinance You have asked that I consider the idea of Council making zoning changes by numbered resolutions and give you my reaction. Wheat Ridge regulates zoning by ordinance (#98) and official zoning map. Since its inception, the city has amended or changed zoning by motion. It is a well established general rule that an ordinance is changed or amended by a substitute ordinance. (I understand that statutory cities Brighton and Broomfield amend their zoning by ordinance--and home rule cities Aurora, Lakewood, end Englewood do likewise.) I understand that an earlier Wheat Ridge administration considered the substitute ordinance procedure and rejected it. While it is not a firm (unquestionable) determination, this decision can find support in CRS '63, 139-60-4, which allows a city to establish its own rules as to the manner in which zoning provisions may be amended, supplemented, or changed. Change or amendment by numbered resolution has the admin- istrative advantage of permitting a more orderly and efficient record keeping. However, numbering and titling of zoni~g motions would meet the resolution advantage. Change and amendment by ordinance would reach general rule/ practice; would alleviate any question about legality of present procedure; would obtain the mentioned ord2rliness and efficiency anc; would, because of the 3: day delav-in beccning effective, permit the public better o~~ortunity to express objection. Jchn A. .Jerman Page Two But, this procedure can be viewed 65 objectionable--two readings, 10 day delay in public hearing, in addition to the 30 days, plus the possibility of 8 public protest resulting in the ordinance being abandoned by Councilor an election (referendum). Parenthetically, some Colorado cities attempt to get around the protest/election by making their substitute ordinance an "emergency" one taking effect in five days--a questionable practice. Perhaps we should discuss this further. WILLIAM E. McCARTHY City Attorney WEM/kkw AMENDED PETITION PETITION FOR ANNEXATION OF UNINCORPORATED TERRITORY IN THE COUNTY OF JEFFERSON, STATE OF COLORADO TO THE CITY OF WHEAT RIDGE, STATE OF COLORADO TO THE MAYOR AND THE CITY COUNCIL OF THE CITY OF WHEAT RIDGE, COLORADO: The undersigned, In accordance with the Municipal Annex- ation Act of 1965, chapter 303, Session Laws of Colorado 1965, and colorado Revised Statutes of 1963 as amended Chapter 139, Article 21, hereby petitions The city council of the city of Wheat Ridge for annexation to the city of Wheat Ridge of the following described unincorporated territory located in the county of Jefferson, state of colorado, to-wit: SEE ATTACHED EXHIBIT "A" In support of the said petition, your Petitioner alleges that: 1. It is desirable and necessary that the above des- cribed territory be annexed to the city of Wheat Ridge. 2. Not less than one-sixth of the perimeter of the area proposed to be annexed is contiguous with the city of Wheat Ridge. 3. A community of interest exists between the territory proposed to be annexed and the city of Wheat Ridge. 4. The territory proposed to be annexed is urban or will be urbanized in the near future. 5. The territory proposed to be annexed is integrated or is capable of being integrated with the city of Wheat Ridge. 6. No land held in identical ownership, whether consist- lng of one tract or parcel of real estate or two or more contiguous tracts or parcels of real estate: (a) is divided into separate parts or parcels without the written consent of the landowner or landowners thereof, unless such tracts or parcels are separated by a dedicated street, road or other public way; (b) comprising ten acres or more which has an assessed value in excess of Seven Thousand Dollars for ad valorem tax purposes for the year preceding the annexation lS included within the territory proposed to be annexed without the written consent of the landowner or landowners. 7. I, Dwaine R. Richter, the slgner of the Petition comprise the landowner of one hundred percent of the territory included in the area proposed to be annexed, exclusive of streets and alleys. 8. The mailing address of the signer, the legal descrip- tion of the land owned by the signer, and the date of signing of his signature are all shown on this Petition. 9. Attached to this petition is the affidavit of the circulator of this Petition that the signature hereon is the signature of the person whose name it purports to be. Your Petitioner further requests that the city of Wheat Ridge approves the annexation of the area proposed to be annexed. SIGNATURE DWAINE R. RICHTER, whose address lS 2860 Berry Lane, Golden, colorado 80401, owns the above described real Jif/Lk/ :{fJ2IL- DWAINE R. RICHTER Date: ,JI/7y -=If'/ / I property. -2- ~ STATE OF COLORADO ! COUNTY OF ;"-. lj;')~ . J' L ss. AFFIDAVIT ~t)1JJ.J-- /' , 1\ ~,J~; c t , being first duly sworn, upon oath, deposes 1. That the affiant circulated the Petition for Annexation herein for the purpose of obtaining the signature of the above petitioner. 2. That the signature thereon is the signature of the person whose name it purports to be. ., ~ _ 'L oJ, ......-1,. ~- I ". . -., , . t ., /lhe /_\ ~~__-1 ....--i ./1 · ~-}7 ~-".-' /"( Subscribed and sworn to before me this~_ day of (. ct ~~ l , 1974. / ~ commission expires: , /, l. I f :/ I J /7 )(, I /';,j r ~'- (,.4.- ,.,ff. {.,t.'.; ,("" /' / v..... '1 {( '-r;,L.c--- (SEAL) -3- EXHIBIT "A" DESCRIPTION ;;:Jcq/nn/nq of fhe norfheo:Jf COf"ner or Loi I) Block I) App ~c.v-den~ 5#/?/;j.j'tj/on.> JeffertJon r:ounfy, Colorado; fhen o long fne .J-":;______';;'":j Ime of Lots 2) 3) 4) 5) G and 7 of 50 C' d/:;Ionce of 468.43 feef to the norfheo:Jf corner of ~ f:7t'nce conft'nu/nq tV 0048.2' W a d'6fance of 50 feef fo f /:One of We::;f 33rd Avenue; thence 5C3:;03:J'W along f-he //ne of hie:;f 33ro A venue a d/5fonce of ~2 feef to fhe corner oT fhe wesf 30 feef of Lot 5; 810ck 4 of :5010 ,- GO,voden!:> .3ubd/v/5/0n; thence N 0048.2' fY along fhe e0:57 the wesf 30 feet of .sa ld Lof 5 a d/5fance of' 130 Tee t fo of .5o;"d Lof 5 JO fhence 58:;o3;)'W alonq the norfher/y I/n.e , 4 a d;~fance of 211.03 feef to a,po/nf IOG2.48 -reef VY //ne of Lot 15) Roxbury Gorden!:>) Jef"rer5on County) Calc N 003 J.3'W parallel 10 fhe e05f I/ne of said Lot /5 a d/5 feef fa the norfh line of .501d Lot 15; fhence 1Y3~o3:;'E ole J/ne of saId Lot 15 a d/::Jfonce of 728.38 feef to a poir. we:3f of fhe norfhea!)f corner of !3old Lot 15) .501d po;'nf >ve5ferly r/qhf-of-way /lne of Inter.5tafe H/qhway No.I .'oufherly along fhe we:3fer/~ righf-of-way //ne of 60ld j- l'ne follovv;'nq -four COUr5efJ: :5 G" 37.S-'W 0 dl6fance of 119., o d/:dance of 2GG.70 feef; 589"40'h/ a dl5fonce of 32.8 :3 G,"3t'y.; 0 dl5rance of' 547.73 feef fo a po/nf 70 reef ne :Jou fA !/ne of fhe (Y W 'It/. of 5ec lion 2:J, T 3 5, R G:; W; fhe! S 00 17~~'E. 0 d/~fance of 70 fee f to fhe 60ufh It'ne of f) 60ld .5ecf/on Z~; fhence /Y89043.5'E along the .5oufh /1 of 5o/d 5ecf/on 29 a d/~fonce of 45G.57 {"eef to fhe .50U cf fhe 5h'Y4- ofihe NH'I4 ofsoid5ecft'on 2~jfhence .5003G'Ealo of the NYz 5h'14. of 5o/d Secf/on 2;3 0 di5fcnce of GO reefj fhen, a Y;'5fonce of w87.84 feet to a pot'nf G35 feet eO:3f of/he we, 5 x}~ of 50id 5ecf/on 2~J' ~::ence ~O~ 39.5 '1;'7 parallel to the west line of the Sh'!:( of said Secb.ion . di~tance of 15 feet; thence S89043.5'W parallel to the north line of t of said Section 29 a distance of 240 feet; thence Noo39.5'W a'distance =2et to the no~th line of the SW~ of said Section 29; thence N0048.2',~ to ~he west line of the m'll:( of said Section 29 a distance of 30 feet t :::o::th line of West 32nd Avenue, as shown on the plat of said Applewood Sucdivision; thence N89043.5'E along the north line of West 32nd Avenu, t~nc~ of 50 fe~t to the intersection of the south line of said Lot 1 w ',Iest line of said Lot 1: thence Noo48.2'W a distance of 95 feet to' the wast co~ne~ of said Lot 1; thence N89043.5'E along the north line of Si ~ d~~tance of 115 feet to point of beginning. ( PETITION FOR ANNEXATION OF UNINCORPORATED TERRITORY IN THE COUNTY OF JEFFERSON, STATE OF COLORADO TO THE CITY OF WHEAT RIDGE, STATE OF COLORADO TO THE MAYOR AND THE CITY COUNCIL OF THE CITY OF WHEAT RIDGE, COLORADO: The undersigned, In accordance with the Municipal Annex- ation Act of 1965, chapter 303, Session Laws of Colorado 1965, and Colorado Revised Statutes of 1963 as amended Chapter 139, Article 21, hereby petitions The city Council of the city of Wheat Ridge for annexation to the city of Wheat Ridge of the following described unincorporated territory located in the County of Jefferson, State of Colorado, to-wit: SEE ATTACHED EXHIBIT "A" In support of the said Petition, your Petitioner alleges that: 1. It is desirable and necessary that the above des- cribed territory be annexed to the City of Wheat Ridge. 2. Not less than one-sixth of the perimeter of the area proposed to be annexed is contiguous with the city of Wheat Ridge. 3. A community of interest exists between the territory proposed to be annexed and the city of Wheat Ridge. 4. The territory proposed to be annexed is urban or will be urbanized in the near future. 5. The territory proposed to be annexed is integrated or is capable of being integrated with the city of Wheat Ridge. 6. No land held in identical ownership, whether consist- lng of one tract or parcel of real estate or two or more contiguous tracts or parcels of real estate: (a) is divided into separate parts or parcels without the written consent of the landowner or landowners thereof, unless such tracts or parcels are separated by a dedicated street, road or other public way; (b) comprising ten acres or more which has an assessed value in excess of Seven Thousand Dollars for ad valorem tax purposes for the year preceding the annexation lS included within the territory proposed to be annexed without the written consent of the landowner or landowners; 7. The signer of the Petition comprlses the landowner of more than fifty percent of the territory included in the area proposed to be annexed, exclusive of streets and alleys. 8. The mailing address of the signer, the legal descrip- tion of the land owned by the signer, and the date of signing of his signature are all shown on this petition. 9. Attached to this Petition is the affidavit of the circulator of this Petition that the signature hereon is the signature of the person whose name it purports to be. Your petitioner further requests that the city of Wheat Ridge approves the annexation of the area proposed to be annexed. SIGNATURE DWAINE R. RICHTER, whose address lS 2860 Berry Lane, Golden, colorado 80401, owns the above described real property. Date: Jt16' C \7./:,' / ~- //c;-'/ V ./ -2- STATE OF COLORADO ) ~1'1'r"r5t'JJf ) COUNTY OF ~ ) ss. AFFIDAVIT \.. /_LuL V-Uj., , , being first duly sworn, upon oath, deposes and states: 1. That the affiant circulated the Petition for Annexation herein for the purpose of obtaining the signature of the above Petitioner. 2. That the signature thereon is the signature of the person whose name it purports to be. G~0~ Vul Subscribed and sworn to before me this~day of ??J~.A: , 1974. SEAL expires, 0,1 /..sJ9''7? ,/ i .0 _~~7/~f: My commission EXH1Jj,n A DESCRIPTION E3eglnn/nq 01 the norfhea:Jf corner of Lof I) Blocl< I) App/ewood Gordens 5ubd/vI5/on) JefrertJon r:oun!y, Colorado; thence IV 0048, 2'yl a/onq the :::;t.;:.{br...-.>:1 line of Lots 2,3) 4,5, r; and 7 of 5o/d Block I a d/5fance of 438.43 feef fa Ine nor/-heo!}! corner of :Jo/d Lol 7; fhence confinu/nq /'10048.2.' W a dt'::dance of 50 Teef fa fhe nOr'fhe,-iy II'ne of Wesf 33rd Avenue; ihence :3!J:J 033'W along +he norfherly (ine of Wesf 33rel Avenue a d/;Jfance of 92. feef to fhe :7oufnea5ferly corner of fhe we5t 30 feef of Lof 5) Bloc/< 4- of 50/'0' Applewaod Garden5 .!3ubdivi5/0n; thence N 0048.2' hi along fhe e05ferly line of the wes! 30 -reef of .sa/d Lof 5 0 di~:;fance of 130 feet fo the north lIne of :scnd Lof 5 j thence 58:J038'W olonq the norfherly Itne of .5ald SiccK 4 a disfonce of 211.03 -reef to a,poin! IOG2.48 ree-l- west of" the eC:3 Ime of Loi 15) Roxbury GardentJ) Jerf'er!7on Counfy) colorado.> fhence N 003 J 3'w porallel fo {he e05f I/ne of 50ld Lot 15 0 d/5fance of 205 feef fo the north !/ne of 5ald Lot 15; thence NtJ'303:J't along fhe ncr+h !/ne of said Lot 15 a d/:3fance of 728.38 feef fa 0 pomt 334. ( -feeT we.5f of the norfhee:J! corner of :Joid Lot /5) 50ld pOinf being on i-he we5ferly right-of-way line of Inter5tare H/qhway No.J>70; fherce 50ufhGrly along the we:3ferl'j rlghl-o/-way line of :JOte! /-I/qfn/lfay _:c~;- -the fo/lowmg four Cour5e!"!' 5G0375Wo dl::dance of /19.2 feefj5Co:'O't o dl5fonce of ZGG. 70 feef.; :; 8~ 040' hi 0 d/5fance of 32 8 feef". ena :3 GO 3;' /4 0 d/5fonce of 547. 73 fee f fa 0 po int 70 reef norfh of fho': :7o'..dh ilne of +he NW'Ic;. of5ecl/on 2:J,T3.5,RG:JW; fhence :; CO !7~4-'E a d/~fance of 70 feet to fhe :5oufh line of the NW'I4 cf :701d 5ectlOn 2:7j thence /y8")043.5'E along the .5oufh line of tne s;../ of 5al'd Section 2'3 a dl5fonce of 45G.57 reef to fhe ..5oulheo:Jf c:Jr,~e,- c;f fh: 5f,-,!0 of the NW!i4 of .5aid 3ecflon 2.'3j fhence 5003C'E along fhe cc:-/ , of fhe Yifiz 3h'Y-;. of 50ld 5ecfton 2'3 0 d/~dcnce of GO reef:, thence 5830c,:.....] C c:),~dQnce of 087.84 feet to 0 painf G35 feef e05f offf.e weST Ime of' .J.,,~ 5:--:/::. 0,>' 5::Jld 5"!cfton 2:)}' t~ence ~0"39.5.W parallel to the west line of the SW~ o~ said Se~b~on 29 a distance of 15 feet; thence S89"43. 5 'w parallel to the north line' of the S\'1':; of said Section 29 a distance of 240 feet; thence Noo39.S'w a distance of 4S :eaet to th'O! north line of the swl;, of said Section 29; thence NOOcj8.2'\,/ ':)Clr31lcl to ~he west line of th~ NWl;, of said Section 29 a distance of 30 feet to'the ;"orth line of \'lest 32nd Avenue. as shown on the plat of said Apple,'Jood G"rd,,~s Subdivision; thence N89043.5'E along the north line of \'lest 32nd Avenue ~ dis- tance of 50 feet to the intersection of the south line of said Lot 1 wit~ t~e west line of said Lot 1; thence NO"48.2'W a distance of 9S feet to the ~orth- ~)est corner of said Lot 1; thence N89043.5'E along the north line of sa,d Lot 1 a difjtance of 115 feet to point of beginning. ! STATE OF COLORADO COUNTY OF A~7WU. '1./ ., 'I \ f:2-rn. -J./ ;\cJ...t..vT tj;...y,-,-~, , being first duly s\\Orn, !j (! upon oath, deposes and states: ss. AFFIDAVIT 1. That the affiant circulated the Petition for Annexation herein for the purpose of obtaining the signature of the above Petitioner. 2. That the signature thereon is the signature of the person whose name it purports to be. r-1/V'V> ~ .,(\~yc 1;t 1:<- ...............-.....---L--.-.........~/J ' :./ , ~-r Subscribed and SWorn to before me this / --- day of (SEAL) ",h,l:~ /y fj 7(, oj' f ' ) ~ct~uJ?: ~-t~L,- , / -3- , EXHIBIT "A" DESCRIPTION 8eq,nn/nq of -the norfhea::Jf corner of Loi I, Block I) Applewood , Gordens 5ubd/v/5/on.> Je!Yer:;on r:ounf'j, Colorado; fhence /'100413.21-1 along the ~';j!'.!!.S!.---r line of Lof5 2, 3} 4,5, G and 7 of 5o/d 810cx I a d/5fance of 488.43 feef fa fhe norfheo::d corner of :laid Loi 7; thence conft'nu/nq IV 0048.2' W a d/6fance of 50 feef fo fhe nor-fhe{'/y J:'ne of We5f 33rd Avenue j thence :3 8:3 033'01 along +he northerly I/ne of We5f 33ro Avenue a d/:;fonce of:32 feet fo Ihe 8oufhea:5rerly corner of fhe wesf 30 feef of Lof 5) Block 4 of :JCI/O Applewood Garden5 .5ubdlvl.5/on; thence N 0048.2' H along fhe eO:5fer/y line of the we:3f 30 feef of 60' ld LvI 5 a d/:,fO'nce of /30 Tee f fo the north /In, of .5cl/d Lof 5 j fhence 58:303f)'W alonq the norfherly I/ne of. .5aid eloc/ 4- a di5fance of 2//.03 feef fo Ci ,po"nt /0 G 2.48 reef we:3t of" fhe eo line of Lol /5) Roxbury GardentJ) Jerf"er:Jon Counfy) Colorado j fhence N 003 !.3'w parallel fo the eo:d I/ne of .5O'/d Lof 15 a d/5fonce of 205 feef fa the north I/ne of ,;')oid Lot 15; fhence Nt3'!)o3:J'E along fhe norf}- I/ne of sold Lof 15 a d/f)fance of 728.38 feef fa 0 pomf 334./ -feef we:3r of fhe norlheO'tJf corner of .5old Lot 15, .5oid pomf be:/nq on fhe we5ferly rlghi-of-woy Ilne ,of :Inrer:dale H/ghwoy No.I-70j fhence 50ufhcrly along the we5fer/'j r/CJ.hf -o,f-woy, I/ne of 6o/d /-Ilqhwoy f:?r, fhe followmg f"our coursefJ: 5 G 37.0 W a d/::Jfonce of 1/9.2 feef j:; 0 30 L a dl5fance of 2GG.70 feef; 58:3040'r; 0 dl5fonce of 32.8 feefJ. end :5 GO 31' vi a d/5tonce of 547.73 feef to a poinf 70 reef north of fhe :)ou Ih //ne of fhe /Y W ';4- of 5ecf/on 2:3, T 35, R. G:3 w; -thence 5 00 17~~'E 0 d/~fO'nce of 70 feef fa fhe :5oufh I/ne of the /'IN '14 of 5'o/d .sect/on 29; thence IYC3:3043.5'E along the .5oufh I/ne of the N0/ of sar'd 5ecf,'on 2:3 a dl':5 fonce of 45G.57 reef to Ihe .,5oulheo:Jf corne,' of the 51-\'% of fhe NW!i4 of said 5ecf/on 2:7; fhence 5003C'E along fhe ec~f./ of fhe NJz 5WJ.4 of 50ld !3ecf/on 29 a d/5fonce of GO feet; fhence 583043.6 ;- o di5fonce of 087.84 feet to a po/nf G35 feef eo::Jf of -Ihe weST line of fhc 5 x;,; of 5o/d 5ectlOrJ 2'3J' ~::ence :-:oo39.s'H parallel to the west line of the SW\ of said Secb;ion 29 a c:i:;;:ance of 15 feet; thence S89043.s't-I parallel to the north line' of the S\,,~ of said Section 29 a distance of 240 feet; thence NOa39.s'W a distance of 45 =2et to the north line of the SW~ of said Section 29; thence Noo48.2'\~ parallel to ':ne west line of the NW~ of said Section 29 a distance of 30 feet to the :-oo::-th line of West 32nd Avenue, as shown on the plat of said Apple\1ood Gardens SUDdivision; thence N89043.S'E along the north line of West 32nd Avenue a oi5- ~a~ce of 50 feet to the intersection of the south line of said Lot 1 with the 'dest line of said Lot 1; thence Noo48. 2 'w a distance of 95 feet to' the north- west corner of said Lot 1; thence N89043.S'E along the north line of said Lot 1 a d~6tance of 115 feet to point of beginning. ! City of Wheat Ridge In this space there is a large scale map that could not be scanned at this time. Please see the City of Wheat Ridge Clerks office if you would like to see the map. Thank You. 1808 residents sign petitions seeking reversal of zoning More than 1800 Wheat Ridge residents are upset with the City Council's handling of the zoning of 10 acres at W 32nd Ave. and Interstate 70. They want the Council either to reverse its decision to approve planned commercial development for the site or put it to a vote of the people. Petitions with 1808 names have been turned in to City Clerk Elise Brougham asking for the repeal or referen- dum on the zoning. She accepted them, subject to the approval of City At- ty Bill McCarthy The City Council will hear a report on the petitions Thursday (tonight) at its study session and will take action by resolution a week later at its regular meeting. Mrs. Brougham said state law requires that referen- dum petitions must contain signatures of at least 15 pet. of the number of persons who voted for mayor in the last election. Since there were 4595 votes cast for mayor Nov 6, 1973, about 690 signatures were required. She said 47 of the peti.tions were circulated by non- residents and only four were circulated by Wheat Ridge residents. Four non-residents from the Applewood Gardens area led the petition drive to repeal the zoning of Dwaine Richter's property at the northwest corner of W 32nd Ave. and 1-70. They were Mary 'C. Dodder, Frank Fraunfelder, Arthur F Brunton and Gary H. Holbrook. Their attorney is Alan C. DeMuth. Richter successfully annexed the property to Wheat Ridge this spring after three tries, and came in for rezon- ing of the land Aug. 29. His outline development plan for planned commercial development zoning was un- animously app1'OV'ed by the CounCll. Council members urged him and the residents op- posing the zoning to get together to work out compatible uses of the property When no effort was made, the Applewood Gardens residents decided to circulate the referendum petitions. Richter has previously tried to rezone the property for duplexes, apartments or restricted commercial uses, before the County Commissioners and later the Wheat Ridge City Council, but was strongly opposed in each attempt. Area residents feel the proposed commercial-I uses are too intense next to a residential area and that the traf- fic problems and hazards for school children will be in- creased. Part of Richter's property has protective covenants on it to restrict development ot low density residential uses. Richter applies_ unoPposed Suppose D . tried to annex~al~e Richter I Ridge and no~ to Wheat I protest? Y came to I That's ex happened last actly What ordinanc week when an : Richter's roe annexing northwest co acres at the Ave a ndrneroC.W 32nd U' 1-70 nammously . was reading by th:~~ed on !irst CIty Council' eat RIdge . ! bu~o~~;hc:~e t~hoPPose it. change, when a~ will comes to the - RIchter rezoning of th cIty for RIC~ter was un e property I obtaming'" successful In , th " rezoni j e COunty ng from HIS first attem to Wheat Rid e pt to annex dIed in a f g and rezone Council. Hl~ ~ote ?f the City . Was approve~con(j attemp't reSIdents Went i but area the de' .0 COurt and CIS I 0 overturned n was main objecti ResIdents' change for c~~ was the zone m their r . merclal Uses borhood. eSldential neigh. .~ During his th. Inclusion in th lrd try for first attempf e cIty. he is and will later ~~~ /0 annex .Change. or a zone 1 Q-acre rezoning faces third attempt Dwaine Richter is back before the Wheat Ridge City Council once again, trying to annex his property to the city and perhaps the third time will be a charm. Richter a ttempted to rezone and annex 10 acres of undeveloped land at the northwest corner of W 32nd Ave. and 1-70, two times before. The first time, the request died with a tie vote. The Council approved his se- cond request despite much op.positon ,of area homeowners. They were OJ>- posed to the 7.8 acres of commerciaH zoning and 1.4 acres of restricted commercial.l property he requested. The case was taken to court, and District Judge Winston Wolvington over. turned the annexation and rezoning because the City Council erred in denying a legal protest by surrounding neighbors. In his third approach to the Wheat Ridge Council, Richter is simply asking for annexation to toe city, retaining its present agriculture-2, residential.} and residential.lA zoning. He called it his "annual . ftillolity.", Helntends to ask. for rezoning later for com. mercial uses_ -I ::0 C 'i en D. Ol < He told the Council he was bringing his dog-eared, beat. up petition for annexation to them again. "I was rejected once, accepted once, and then disected by the District Court_ " :P -a 'i 1-'. I--' ... City Attorney Bill McCarthy told the Council members they could annex the property by ordinance without the normal hearings. Alderman Louise Turner made a motion the the Richter Annexation procede by ordinance, and that the public works and planning departments check out the petition, so that action may be taken on it at the study session Thursday (tonight) The motion was approved. A public hearing will then be held April 11 when the or. dinance comes up on first reading. Alderman Larry Merkl voted against Mrs, Turner's motion to protest the rush treatment. "What's the hurry?" he said. "I hear a railroad. " Richter lives at 2860 Berry Lane. Golden: . -' Ul -.J ... -I ::0 ro E ::0 ro Ol c+ ::0 1-" D. lD ro u: ro :J ci I-' :J ro I- ., o u:: n