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,
, 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