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Resident Files Injunction against the City of Loveland

Loveland business owner and resident Bill Jensen has filed an injunction against the City of Loveland. He has shared the documents filed with the Court this week (located below this interview) and also agreed to a Q and A about why he chose to take action.

EDITED June 7, 2023 with filed amendments

June 03. 2023

The Loveland Voice: What did you file with the court this week, and what does it relate to? 

Bill Jensen: I filed a “Complaint for Injunctive Relief” regarding the City Council’s recent URA public hearing.

TLV: What court did you file it with? 

Jensen: The 8th District Court in Fort Collins.

TLV: What motivated you to this? 

Jensen: I’m not a supplicant. My rights exceed authority. 

TLV: What happens next? 

Jensen The sheriff’s department will serve the summons any day now and then the defendant will motion for a dismissal.

TLV: What is your goal with this injunction? Is there an ideal outcome? 

Jensen: I want Colorado Law enforced, to stop agricultural land included into an Urban Renewal Plan. I’m seeking that City Resolution #R-50-2023 annulled.  I’m also seeking “exemption E” adjudicated to mean that a preexisting agricultural URA may not have its original sunset extended.  One sunset only. Indeed, The Defendant’s interpretation and application of Exemption E is without basis, as it renders the complete statute fruitless.

TLV: What should Lovelanders understand about the potential impact this could have? 

Jensen: An annulment could put Centerra South on the back burner indefinitely. A successful adjudication would kill it until a higher court reverses it. 

TLV: How can we follow the progress of the case? 

Jensen: Follow The Loveland Voice

TLV: You’re filing pro se (without legal representation). What motivated you to make that choice? 

Jensen: I see simple unlawfulness violating obvious state statutes.  I see a lot of money going the wrong way.  I see an arrogant and obtuse local government.   City Hall colludes with their Favorites, building monopolies and exclusive wealth centers; it’s done under our noses with impunity.  

We are a Banana Republic not acting in good faith, as found in District Court last year (City of Loveland vs Jacki Marsh).

TLV: What would you say to residents who are unhappy with decisions or actions the City of Loveland is making, but feel helpless to impact the outcome? 

Jemsen: Critique your helplessness; it’s not real

TLV: Anything else you want us to know? 

Jensen: Within our community, true leaders exist. Seek them out. Mobilize.

EDITED with additional amendments filed June 7, 2023

Editor’s note: These amendments have been updated to reflect the actual amendments filed by Jensen on June 8, 2023.

Amendment One with exhibits 11, 12, 13 & 14 

Whereas, a majority of councilors did write two letters, without a statutory public hearing (April 19 & 27) with the intent to influence the legislature and also the governor concerning Urban Renewal legislation in process, specifically to amend & clarify "Exemption E"  (SB23-273). -Exhibits 11, 12 & 13

Therefore, the Defendant improperly denied the public’s due process and knowledge of altering local statewide concerns.  The Plaintiff will show that the content of the said unapproved letters is false and misleading; the quantity of affordable homes discussed in the letters is not substantiated (exhibit 14).  The actual number of affordable homes in the existing Centerra URA is markedly lower. Shortly afterwards, Gov. Polis made a rare veto of the legislature’s attempt to clarify “Exemption E.”  (SB23-273)  The Court may infer that The Defendant’s unapproved letters must have played a part in this rare veto. 

These described actions demonstrate Open Meeting Law violations; therefore, implying the Defendant's intent at the May 2 URA public hearing was premeditated to ignore the public's input altogether.  This premeditation is a grotesque violation of the public’s trust and its right to due process.

The Plaintiff respectfully asks the Court to consider the dates of the letters and the date of the May 2 public hearing, as they relate to the ongoing legislative process amending "Exemption E." 

The Plaintiff asserts that a common pattern of the Defendant’s behavior exists: 

1) an improperly noticed URA public hearing on May 2

2) two unapproved letters, with City letterhead, containing falsehoods, addressed to the Capitol Building during the legislative session, relating to the clarification of Exemption E (exhibits 11, 12, 13 & 14)

3) a never applied interpretation of "Exemption E" described in the Defendant’s aforementioned City Resolution # R-50-2023. (This interpretation is without basis, as it renders the statute fruitless.)

These three items are all related to 155 million local tax dollars diverted to one exclusive private development with no public benefit (exhibit 14).  This single location in question adjoins similar ongoing developments which are receiving no public tax diversion assistance.  This singular access to public assistance relates to findings made by the Hon. Juan Villasenor, 8th District: City of Loveland v. Jacki Marsh, 2022;  The Loveland Government is a Banana Republic not acting in good faith.

Amendment Two (alters nothing preceding it)

Whereas, the Plaintiff, a Loveland resident, has a legal relationship with The Defendant,  The Loveland City Council, a local public body, his local taxing government.  The Plaintiff may challenge his local taxing government when his due public process rights are denied concerning his local public tax dollars of statewide concern.   Indeed, he may legally stand in court concerning these aforementioned allegations.  [U.S. 14th Amendment, CRS 31-25-107 (3)(a), CRS 31-25-102(4)(b)]

Amendment Three

Please add new exhibit #10 to further support Allegation One. Exhibit #10, Council Meeting Minutes, April 18, 2023,  demonstrates the Defendant creates non statutory procedures to skirt the black-letter law. CRS 31-25-107(3)(a).  Here, these creative procedures deny the public’s right to due process for an Urban Renewal public hearing of statewide concern.  CRS 31-25-102(4)(b)

Bill Jensen is the owner of the Head Zeppelin Barbershop in downtown Loveland. He is active in local politics and believes in the power of community.


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