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DATE FILED: January 12, 2024 12:24 PM
DISTRICT COURT, MONTROSE COUNTY, FILING ID: 56CA72FFD5174
COLORADO CASE NUMBER: 2024CV30005
Court Address: 1200 North Grand Avenue, Bin A
Montrose, CO 81401
SUZETTE WILLIAMS, as next friend of DEREK
WHITAKER, minor child,
Plaintiff, ▲COURT USE ONLY▲
-versus-
HECTOR LARA and YVONNE MUZZY as next friend
of ANDRES PEREZ, minor child,
and
HECTOR LARA,
and
YVONNE MUZZY,
Defendant.
Counsels for Plaintiff:
Joseph Moulton, Reg. No. 56907
DezaRae D. LaCrue, Reg. No. 40290 Case No.:
FRANKLIN D. AZAR & ASSOCIATES, P.C.
14426 East Evans Avenue Division:
Aurora, Colorado 80014
Phone:(303) 757-3300
Fax: (303) 759-5203
E-Mail: moultonj@fdazar.com
E-Mail: lacrued@fdazar.com
DISTRICT COURT CIVIL (CV) CASE COVER SHEET FOR INITIAL
PLEADING OF COMPLAINT, COUNTERCLAIM, CROSS-CLAIM
OR THIRD-PARTY COMPLAINT
1. This cover sheet shall be filed with the initial pleading of a complaint, counterclaim, cross-
claim or third party complaint in every district court civil (CV) case. It shall not be filed in
Domestic Relations (DR), Probate (PR), Water (CW), Juvenile (JA, JR, JD, JV), or Mental
Health (MH) cases. Failure to file this cover sheet is not a jurisdictional defect in the pleading
but may result in a clerk’s show cause order requiring its filing.
2. Simplified Procedure under C.R.C.P. 16.1 applies to this case unless (check one box below if
this party asserts that C.R.C.P. 16.1 does not apply):
This is a class action, forcible entry and detainer, Rule 106, Rule 120, or other similar
expedited proceeding, or
■ This party is seeking a monetary judgment against another party for more than
$100,000.00, including any penalties or punitive damages, but excluding attorney fees,
interest and costs, as supported by the following certification:
By my signature below and in compliance with C.R.C.P. 11, based upon information
reasonably available to me at this time, I certify that the value of this party’s claims
against one of the other parties is reasonably believed to exceed $100,000.”
Or
Another party has previously filed a cover sheet stating that C.R.C.P. 16.1 does not apply
to this case.
3. This party makes a Jury Demand at this time and pays the requisite fee. See C.R.C.P.
(Checking this box is optional.)
Respectfully, submitted on this 12th day of January, 2024.
FRANKLIN D. AZAR & ASSOCIATES, P.C.
By: /s/ Joseph C. Moulton
Joseph C. Moulton, Reg. No. 56907
Dezarae LaCrue, Reg. No. 40290
ATTORNEYS FOR PLAINTIFF
NOTICE This cover sheet must be served on all other parties along with the initial pleading of a complaint,
counterclaim, cross-claim, or third-party complaint.
2
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DATE FILED: January 12, 2024 12:24 PM DISTRICT COURT, MONTROSE COUNTY, FILING ID: 56CA72FFD5174 COLORADO CASE NUMBER: 2024CV30005 Court Address: 1200 North Grand Avenue, Bin A Montrose, CO 81401 SUZETTE WILLIAMS, as next friend of DEREK WHITAKER, minor child, Plaintiff, ▲COURT USE ONLY▲ -versus- HECTOR LARA and YVONNE MUZZY as next friend of ANDRES PEREZ, minor child, and HECTOR LARA, and YVONNE MUZZY, Defendant. Counsels for Plaintiff: Joseph Moulton, Reg. No. 56907 DezaRae D. LaCrue, Reg. No. 40290 Case No.: FRANKLIN D. AZAR & ASSOCIATES, P.C. 14426 East Evans Avenue Division: Aurora, Colorado 80014 Phone:(303) 757-3300 Fax: (303) 759-5203 E-Mail: moultonj@fdazar.com E-Mail: lacrued@fdazar.com DISTRICT COURT CIVIL (CV) CASE COVER SHEET FOR INITIAL PLEADING OF COMPLAINT, COUNTERCLAIM, CROSS-CLAIM OR THIRD-PARTY COMPLAINT 1. This cover sheet shall be filed with the initial pleading of a complaint, counterclaim, cross- claim or third party complaint in every district court civil (CV) case. It shall not be filed in Domestic Relations (DR), Probate (PR), Water (CW), Juvenile (JA, JR, JD, JV), or Mental Health (MH) cases. Failure to file this cover sheet is not a jurisdictional defect in the pleading but may result in a clerk’s show cause order requiring its filing. 2. Simplified Procedure under C.R.C.P. 16.1 applies to this case unless (check one box below if this party asserts that C.R.C.P. 16.1 does not apply): This is a class action, forcible entry and detainer, Rule 106, Rule 120, or other similar expedited proceeding, or ■ This party is seeking a monetary judgment against another party for more than $100,000.00, including any penalties or punitive damages, but excluding attorney fees, interest and costs, as supported by the following certification: By my signature below and in compliance with C.R.C.P. 11, based upon information reasonably available to me at this time, I certify that the value of this party’s claims against one of the other parties is reasonably believed to exceed $100,000.” Or Another party has previously filed a cover sheet stating that C.R.C.P. 16.1 does not apply to this case. 3. This party makes a Jury Demand at this time and pays the requisite fee. See C.R.C.P. (Checking this box is optional.) Respectfully, submitted on this 12th day of January, 2024. FRANKLIN D. AZAR & ASSOCIATES, P.C. By: /s/ Joseph C. Moulton Joseph C. Moulton, Reg. No. 56907 Dezarae LaCrue, Reg. No. 40290 ATTORNEYS FOR PLAINTIFF NOTICE This cover sheet must be served on all other parties along with the initial pleading of a complaint, counterclaim, cross-claim, or third-party complaint. 2