— COPY BRIANE NELSON MITCHELL (SB 2546) BAU euUNCOWNE. : 3st one Ph to ure Ses Omes box — ; en ‘ephee:(00) 856 rN essay ‘Telephone: (208) 345.2654 eesimlle (208) 345-3319. ‘THOMAS A. BANDUCCT (SH #2453) handel WADET, WOODARD (SB #6312) BAR EAGER HD ‘SaNDUECT WOODARD scawarerzean, PLLC 802 W. Brnnock Stes. Site $00 Boise idaho 83702 ‘Tolephone: (208) 342-4411 aes: 208) 342-4455 Atornys for Pits IN TIE DISTRICT COURT OF THE THIRD JUDICIAL DISTRICT OF THE ‘STATE OF IDAHO, IN AND FOR THE COUNTY OF PAYETTE cueNo._ CY= 2012 Alaly TI JOHN W. BURLILE, an individual; H BOOK LLG, an ldsbo Lines Lihilty Conapeny, CLIFFORD D. MORGAN and MARY A. |MORGAN, individually and as husband aad wife; TOM PENCE, an individual CYRIL W. ROLAND and IRENE J ROLAND, individually and as hnsband and wile ‘THOMAS G. ROLAND and MARCIA R, ROLAND, individually and as husband sd wifl; JAMES $. UNDERWOOD, JR, «9 DRCLARATORY JUDGMENT, AND individual; and JEFFREY G. WEBER, en OTHER EQUITABLE RELIEF hi 7 ) ; ; } > coman angus on d ; ; soe } eysute soe d } d - j y d INFUNCTIVE RELIEF, Pras, ALTERNATE ENERGY HOLDINGS, INC, ‘Novnla Corporation; DONALD L, GILLISPIE, ‘a individu; JENNIFER RANSOM, an individual; COUNTY OF PAYBTTE, polial subdivision of te Sats of ako and ‘DOES 1-10, fttiouly narod, Defentane COMPLAUVT; REQUES! FOR INJUNCTIVE RELIKE, DECLARATORY JUDGMENT, AND OTHER EQUITABLE RELIEF 1COME NOW The Plants and for causes of ation agains! the Defendants, sae allege and aver as follows: Parties 1. Plaintiff John W. Buslile is @ property owner in Payette County and resides at 58105 Lite Willow Road in Payete County 2. Phintff Hl Hook LLC is an Idaho Limited Liability Company that owns and operates the H Hook Ranch in Payette County (refered to as “H Hook Ranch’) tht is located at 10495 Stone Quarry Road. 3, Cliford and Mary Morgan are property owners in Payette County and reside at 74085 Litle Willow Road in Payete County 4, Tom Pence isa property owner in Payette County and resides at $433 Big Willow Road in Payette County 5. Cyl W. and Irene I. Roland are property owners in Payette County and reside at 4001 Litle Witlow Road in Payee County. 6. Thomas G, and Marcia R. Roland are property owners in Payete County and reside at 4331 Lite Willow Road in Payette County. 7. James $. Underwood, J. is property owner in Payette County and resides at 8720 Lite Willow Road in Payette County. 8 _Iefrey G. Weber is a propeny owner in Payette County and resides at 1046S Stone Quarry Roa in Payette County 9. Defendant Altemate Energy Holdings, In. “AEHI") was founded by Donald L Gillispie and incorporated in Nevada with its pineal place of business in Eagle, Kaho. APH is. development stage company that purposely plans to build a nuclear power plat in Payette ‘COMPLAINT, REQUEST FOR INJUNCTIVE RELIEF, DECLARATORY JUDGMENT, AND OTHER EQUITABLE RELIEF -2County on a $00 acre parcel of land that is located between Little Willow Road to the north, Stone Quarry Road to the east, and Big Willow Road tothe south. 10. Defendant Donald L. Gillispie has been President, CEO, and Chairman of AEH a Teast singe the company went publi in 2006, Gillispie sides in Eagle, Idaho, AEHL reported that Gillispie owned 39,600,000 ofits shares (15.9%) as ofthe end of 2009 11, During the relevant peti, Defendant Jennifer Ransom was Senior Vice- President of Adminstration and Seoretary for AEHI, tn 2008, she was given responsibility for ABH administration, human resources, accounting and retited stock sles. Ransom resided in Star, Kaho, bad a personal relationship with Donald Gilispe and was the beneficiary of his TRA. account. ABHI reported that Ransom owned 17,000,000 ofits shares (6.74%) a8 ofthe end of 2009, ofthe Stat of Idaho. 12, Defendant County of Payette is a politieal subdiv 13, Defendant DOES 1-10 are individuals and entities whose true names are unknown in this matter sharing responsitlity andor lability forthe misconduct and wrongdoing ofthe ote Defendants Jurisdiction And Venue 14, This court has subject mater juristiton and personel jurisdition pursuant to [dao Code, Section 5-514, The amount in controversy exceeds the amount of $10,000. 15. Venue is proper with this Cour because the wrongdoing described herein occur in Payette County Summary Of The Action 16, This matter arses out ofthe injures and ireparable harm to Pail that have been and are being eaused by Payette County's participation in and material assistance to the COMPLAINT, REQUEST FOR INJUNCTIVE RELIEF, DECLARATORY JUDGMENT, AND OTHER EQUITABLE RELIEF -3