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Amended Complaint - July 29, 2011 Version 3

Amended Complaint - July 29, 2011 Version 3

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Published by Bryce Crawford
Here is our amended lawsuit — that includes the new CDPHE rules that go into effect on Sunday (though the CDPHE has not posted them as of now) and if I don't mind sayin' — a damn good attack on what the state has done to harm patient and caregiver access to MMJ.

Puff, Puff, Pass, (Chief Greenbud)

Kathleen Chippi
PCRLP founder
Here is our amended lawsuit — that includes the new CDPHE rules that go into effect on Sunday (though the CDPHE has not posted them as of now) and if I don't mind sayin' — a damn good attack on what the state has done to harm patient and caregiver access to MMJ.

Puff, Puff, Pass, (Chief Greenbud)

Kathleen Chippi
PCRLP founder

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Published by: Bryce Crawford on Aug 02, 2011
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05/21/2012

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1DISTRICT COURT, CITY AND COUNTY OFDENVER, COLORADO
1437 Bannock Street, Room 431Denver, Colorado 80202 _______________________________________________ 
PATIENT CAREGIVER RIGHTS LITIGATIONPROJECT, COLORADO PATIENTS’ ALLIANCE,KATHLEEN CHIPPI, and RICO COLIBRI,Plaintiffs,v.STATE OF COLORADO, JOHN HICKENLOOPER,GOVERNOR OF THE STATE OF COLORADO,BARBARA BROHL, EXECUTIVE DIRECTOR OFTHE COLORADO DEPARTMENT OF REVENUE,and MARTHA E. RUDOLPH, EXECUTIVEDIRECTOR OF THE COLORADO DEPARTMENTOF HEALTH AND ENVIRONMENT,Defendants. ________________________________________________ 
Attorney for Plaintiffs: Name: Andrew B. ReidAddress: Springer and Steinberg, P.C.1600 Broadway, Suite 1200Denver, Colorado 80202Phone Number: (303) 861-2800FAX Number: (303) 832-7116E-mail:areid@springer-and-steinberg.comAtty. Reg. No.: 25116
COURT USE ONLY
_______________________ Case No.: 2011-CV-4632Div.: ____ Ctrm: 209
AMENDED COMPLAINT FOR DECLARATORY JUDGMENTAND INJUNCTION PURSUANT TO C.R.C.P. 57 AND 65
PLAINTIFFS, Patient Caregiver Rights Litigation Project, Colorado Patients’ Alliance,Kathleen Chippi, and Rico Colibri, by and through their counsel, Andrew B. Reid of the law firm
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of Springer and Steinberg, P.C., hereby allege and aver the following as their AmendedComplaint for Declaratory Judgment and Injunction Pursuant to C.R.C.P. 57 and 65, and C.R.S.§§ 24-4-101,
et. seq.
, against the Defendant State of Colorado and all of its subdivisions, theDefendant John Hickenlooper as the Governor of the State of Colorado, the Defendant BarbaraBrohl as the Executive Director of the Colorado Department of Revenue, and the DefendantMartha E. Rudolph as the Executive Director of the Colorado Department of Public Health andEnvironment, in their official capacities.
I. PARTIES, JURISDICTION, AND VENUE
1.Plaintiff Patient Caregiver Rights Litigation Project (“PCRLP”) has its principallocation in City of Nederland, Boulder County, State of Colorado. PCRLP is a group of Colorado registered and non-registered medical marijuana patients, primary care-givers, and physicians, and others associated with the provision of medical marijuana medication toqualifying patients and primary care-givers from Colorado having as its purpose the protection of the public through the reformation of the medical marijuana laws in Colorado. The PCRLP andits members have actively participated in the public hearings and comments pertaining to themedical marijuana legislation and agency rule-making.2.Plaintiff Colorado Patients' Alliance (“CPA”) has as its principal location in theCity and County of Denver, State of Colorado, and is a non-profit organization working for therights of medical marijuana patients and caregivers in Colorado. Members include a broad baseof Colorado patients, caregivers, medical marijuana centers, other organizations, and companiesthat believe that a responsible and constitutional approach to the regulation of medical marijuana benefits the public, including those who are patients, caregivers and operational members of the
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medical marijuana industry. The CPA and its members have actively participated in the publichearings and comments pertaining to the medical marijuana legislation and agency rule-making.3.Plaintiff Kathleen Chippi (“Chippi”) is a resident of Nederland, Colorado, and aPCRLP founding member. She is a qualifying medical marijuana patient and, until theenactment of the medical marijuana legislation
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, operated a profitable and viable medicalmarijuana primary care-giving service from Nederland for numerous qualifying patients inwhich, among other care-giving services, she manufactured, sold, and dispensed medicalmarijuana medication to her qualifying patients. She obtained most of her medical marijuanafrom patients and care-givers having small amounts of personal overflow which she redistributedto her qualifying patients. She had and has a state-issued retail sales tax license for medicalmarijuana and has collected and paid sales tax to the appropriate local governments and theState. As a result of the medical marijuana legislation and the regulations thereunder and their restrictions on patients and care-givers set described in this Amended Complaint, she could nolonger continue operating profitably or legally under the legislation and regulations as a primarycare-giver and had to cease her services and suffered therefrom considerable loss in past, current,and future profits and income as a primary care-giver. Upon the resolution of the issues raised inthis petition, it is Ms. Chippi’s intent to reopen and continue her caregiver services.4.Plaintiff Rico Colibri (“Colibri”) is a resident of the City and County of Denver,State of Colorado, and a member of Plaintiff CPA. He is a qualifying medical marijuana patientand, until the enactment of the medical marijuana legislation and regulations, operated a medical
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House Bill 10-1284 (2010); Senate Bill 10-109 (2010); and House Bill 11-1043 (2011), codifiedin a number of different sections of the Colorado Code. To avoid confusion, this legislation will be referred to in this petition collectively as “the medical marijuana legislation”.
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