Financial Records Request

Anonymous natural person(s) filed this request with the Prairie View Ranch Water District, Llc of Colorado.
Due July 19, 2021
Est. Completion None
Status
Awaiting Response

Communications

From: Anonymous natural person(s)

To Whom It May Concern:

Pursuant to the Colorado Open Records Act, we hereby request the following records:

Copies of any and all asset and financial records and documents belonging to, related to, received by, transmitted from, or held by Colorado Special District "Prairie View Ranch Water District, LLC" Colorado DOLA ID# 65978 ("the District") ( https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978 ) that are subject to Colorado Open Records Act (CORA). These documents and records shall be collectively referred to as "Materials". The scope of the Materials shall include all financial and asset subject matters, including but not limited to: income, revenue, expenses, taxes, Elections, real-estate, budgets, reports, records, assets, exchanges, transfers, trades funds, water tap fees, plant investment fees, Colorado Public Deposit Protection Act, payments, compensation, water distribution systems, construction and construction equipment, water rights, and the water wells having Colorado Division of Water Resources Final Permit numbers 1253-RFP, 1254-RFP and 1255-RFP.

This request shall also include Materials regarding payments and/or compensation to District Board members including Daniel Harrison, and the District's subcontractors and service providers, including the business entity known as "Harrison Homes Inc" or "Harrison Homes LLC" having CO Secretary Of State business entity ID# 20181519933.

This request shall also include any and all Materials involving asset or financial transactions with the similarly-named yet distinct business entity "Prairie View Ranch Water District LLC" having CO Secretary Of State business entity ID# 20041352078.

This request shall also include any and all Materials involving the entity(ies) "G&P Enterprises" referred to in the document "RULES and REGULATIONS FOR WATER SERVICE" with heading "Prairie View Ranch Water District LLC 2015-2016" (attached to this request for reference).

This request shall further include any and all Materials that are required by law to be submitted to the State of Colorado and/or Morgan County, such as "Oath Of Office", Bonds, Sureties, "Application for Exemption from Audit", and the missing "Annual Budget" documents for years 2015, 2016 and 2017 that are not on file with Colorado Department of Local Affairs at https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978&category=1&jfwid=B5qt151NguWJVfzZ76NvXbwIt0QSYDI0NAAykOIr%3A0

The Produced materials shall be Transmitted in standard, searchable, sortable format whenever possible. If Materials which have been deleted can be un-deleted or otherwise recovered or restored, such as from an internet backup, court order, or subpoena, the Materials shall also be IN-scope of this request.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

As of the date of this request, the District does not have a written and published CORA Policy on file viewable to the Public in order to notify the Public in advance of the fees, therefore the District cannot charge fees for production or transmission of the requested Materials. The following URL links to a PDF document from the law offices of Seter & Vander Wall, P.C. explaining the essentials of how CORA applies to Special Districts: https://svwpc.com/wp-content/uploads/2016/08/CORA-Webinar-re-HB-14-1193-Seter-and-Vander-Wall-PC.pdf

In the unlikely case that there is a valid CORA Policy published and viewable to the Public prior to this request, we would be grateful if you would provide a total cost for the records retrieval. We would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. We look forward to receiving your response to this request within 30 days.

Sincerely,

Parties concerned with CO Public Water System ID# CO0144621

From: Prairie View Ranch Water District, Llc

I am in receipt of your letter of 06/30/2021. I am in the process of
responding to your requests.

Doryea Gibbs

From: Anonymous natural person(s)

Dear Records Custodian,
We kindly ask that your Local Government Agency expedite the following specific Record during your retrieval of "any and all financial records":

A list of all 85 Prairie View Ranch Water District "service taps" (water taps, or Plant Investment Fees), the sale date, and sale price.

Here is an example of the data being requested:
# Status Sale Price Sale Date
2 SOLD $15,000 7/6/2004
7 SOLD $15,000 5/23/2006
4 SOLD $15,000 8/24/2006
10 SOLD $15,000 5/9/2007
9 SOLD $17,000 7/31/2008
1 SOLD $17,000 6/24/2011
34 4SALE $30,000 Unsold
39 4SALE $30,000 Unsold
44 4SALE $30,000 Unsold

Based on available public financial records, we cannot locate most of the water tap dollars. Your budget for 2021 only shows a $2100 bank balance, but there have been 52 water taps sold at a price of $15,000 to 30,000 each.
In order to maintain Public trust in Local Government, and Elections integrity, a 3rd party public financial audit is necessary. Please produce and transmit all of the District's financial records as soon as possible so that they may be audited by the Public.

Thank you for your Agency's cooperation with the Colorado Open Records Act. We look forward to a speedy response to this records request.

From: Prairie View Ranch Water District, Llc

Please send requests to jchmil@lyonsgaddis.com

From: Anonymous natural person(s)

To Whom It May Concern,

The Records Custodian for Special District "Prairie View Ranch Water District, LLC" DOLA ID# 65978 has referred another CORA request to your email address.

The original CORA request was made on July 5, was acknowledged on July 6, but there have not yet been any responsive records produced as of July 19. On July 19, we requested the Agency expedite one specific document being requested: "A list of all 85 Prairie View Ranch Water District "service taps" (water taps, or Plant Investment Fees), the sale date, and sale price."

Here is an example of the data:
# Status Sale Price Sale Date
2 SOLD $15,000 7/6/2004
7 SOLD $15,000 5/23/2006
39 4SALE $30,000 Unsold
41 4SALE $30,000 Unsold

The text of the original request is as follows:

Pursuant to the Colorado Open Records Act, we hereby request the following records:

Copies of any and all asset and financial records and documents belonging to, related to, received by, transmitted from, or held by Colorado Special District "Prairie View Ranch Water District, LLC" Colorado DOLA ID# 65978 ("the District") ( https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978 ) that are subject to Colorado Open Records Act (CORA). These documents and records shall be collectively referred to as "Materials". The scope of the Materials shall include all financial and asset subject matters, including but not limited to: income, revenue, expenses, taxes, Elections, real-estate, budgets, reports, records, assets, exchanges, transfers, trades funds, water tap fees, plant investment fees, Colorado Public Deposit Protection Act, payments, compensation, water distribution systems, construction and construction equipment, water rights, and the water wells having Colorado Division of Water Resources Final Permit numbers 1253-RFP, 1254-RFP and 1255-RFP.

This request shall also include Materials regarding payments and/or compensation to District Board members including Daniel Harrison, and the District's subcontractors and service providers, including the business entity known as "Harrison Homes Inc" or "Harrison Homes LLC" having CO Secretary Of State business entity ID# 20181519933.

This request shall also include any and all Materials involving asset or financial transactions with the similarly-named yet distinct business entity "Prairie View Ranch Water District LLC" having CO Secretary Of State business entity ID# 20041352078.

This request shall also include any and all Materials involving the entity(ies) "G&P Enterprises" referred to in the document "RULES and REGULATIONS FOR WATER SERVICE" with heading "Prairie View Ranch Water District LLC 2015-2016" (attached to this request for reference).

This request shall further include any and all Materials that are required by law to be submitted to the State of Colorado and/or Morgan County, such as "Oath Of Office", Bonds, Sureties, "Application for Exemption from Audit", and the missing "Annual Budget" documents for years 2015, 2016 and 2017 that are not on file with Colorado Department of Local Affairs at https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978&category=1&jfwid=B5qt151NguWJVfzZ76NvXbwIt0QSYDI0NAAykOIr%3A0

The Produced materials shall be Transmitted in standard, searchable, sortable format whenever possible. If Materials which have been deleted can be un-deleted or otherwise recovered or restored, such as from an internet backup, court order, or subpoena, the Materials shall also be IN-scope of this request.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

As of the date of this request, the District does not have a written and published CORA Policy on file viewable to the Public in order to notify the Public in advance of the fees, therefore the District cannot charge fees for production or transmission of the requested Materials. The following URL links to a PDF document from the law offices of Seter & Vander Wall, P.C. explaining the essentials of how CORA applies to Special Districts: https://svwpc.com/wp-content/uploads/2016/08/CORA-Webinar-re-HB-14-1193-Seter-and-Vander-Wall-PC.pdf

In the unlikely case that there is a valid CORA Policy published and viewable to the Public prior to this request, we would be grateful if you would provide a total cost for the records retrieval. We would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. We look forward to receiving your response to this request within 30 days.

Sincerely,

Parties concerned with CO Public Water System ID# CO0144621

From: Anonymous natural person(s)

Dear Records Custodian,
The alternate email contact that you provided has not acknowledged receipt of our inquiry after 3 working days.

The Local Government agency "Prairie View Ranch Water District, LLC" is not exempt from the Colorado Open Records Act.
https://leg.colorado.gov/sites/default/files/colorado-open-records-act-cora.pdf
"If a court determines that a custodian of a public record has improperly denied the right of inspection of a public record under CORA, the court must award court costs and reasonable attorney fees to the prevailing party. If a person willfully and knowingly violates CORA, the person commits a misdemeanor punishable by a fine of not more than $100, imprisonment in county jail for not more than 90 days, or both."

We ask that you please provide the requested records as soon as possible.
Thank you.

From: Prairie View Ranch Water District, Llc

Good morning,

The District is working to determine what records may be responsive to your request. Regarding your original request, pursuant to Section 24-72-203(3)(b)(I), C.R.S., extenuating circumstances exist which support an extension of the standard 3 day response time due to your broadly stated request which encompasses a large category of records that is without sufficient specificity to permit collection within 3 days. Regarding your expedited request, pursuant to Section 24-72-203(3)(a), C.R.S., it appears responsive records, if any, are in storage and the District will respond when the custodian has the ability to access the stored records.

Sincerely,

[cid:image001.jpg@01D77FA3.5AACCD70]

John Chmil
Attorney

jchmil@lyonsgaddis.com<mailto:jchmil@lyonsgaddis.com>
P.O. Box 978
Longmont, CO 80502-0978
P: 303-776-9900 | F: 303-776-9100
lyonsgaddis.com<https://linkprotect.cudasvc.com/url?a=https%3a%2f%2furldefense.proofpoint.com%2fv2%2furl%3fu%3dhttps-3A__linkprotect.cudasvc.com_url-3Fa-3Dhttps-253a-252f-252furldefense.proofpoint.com-252fv2-252furl-253fu-253dhttp-2D3A-5F-5Fwww.lgkhlaw.com-5F-2526d-253dDwMFAg-2526c-253deuGZstcaTDllvimEN8b7jXrwqOf-2Dv5A-5FCdpgnVfiiMM-2526r-253dxsjgMfOceesTINZVIDOz3JSjGMtR0tquKXxXEqWTpvE-2526m-253dLIIK4DvPy4qOh1kJ4Rj8ndY15pTCpyJxkakl7zyQch4-2526s-253d0vHR9DmLJTq0FLgDeLEBZGPl46Rdm6TafvmxXcv0ROs-2526e-253d-26c-3DE-2C1-2CkpdiMPj0Iv31TZ9lC-2D-2DjENiWgeKHVDcmz2SjO5-5FO9dXSLrTl8xcZUIVrYZE8Rrlyq9VLmaN5wHuqdFfRFlX6JBnlH2MvHI-5FAY4catl7Rc9-2DxAsKeOMR7NV5UEtE-2C-26typo-3D1%26d%3dDwMF-g%26c%3deuGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM%26r%3dxsjgMfOceesTINZVIDOz3JSjGMtR0tquKXxXEqWTpvE%26m%3dSckMKyH5lfmRHX0jk25NSLSwcd9va9jFNXtTAunM8lc%26s%3dPAXZgOQAn0aivOGSp5pAX26cXPl8cieMX_cruYXxVjA%26e%3d&c=E,1,S9Y0Ul7QNcRtoNn8ucIeb9GelAnYB1jgn1nV-OziQ8SIEsykGApl3JeQnIYk5XKBncsxmPjzTZXqMbWAzSPwuNaL0zPQjQ_TeWKbRs5-3fajo9jejDbaLQ,,&typo=1>

CONFIDENTIALITY STATEMENT: THIS E-MAIL MESSAGE AND ANY ACCOMPANYING DOCUMENTS CONTAIN INFORMATION WHICH IS ATTORNEY CLIENT PRIVILEGED, CONFIDENTIAL AND INTENDED ONLY FOR THE USE OF THE ABOVE-NAMED RECIPIENT. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, PRINTING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS MESSAGE IN ERROR, PLEASE IMMEDIATELY NOTIFY US BY TELEPHONE OR RETURN THE E-MAIL MESSAGE TO US. THANK YOU.

From: Anonymous natural person(s)

We are in receipt of your acknowledgement of this request. Thank you for your assistance.

From: Anonymous natural person(s)

Good morning,
Pursuant to C.R.S. Section 24-72-203(3)(a), we kindly ask that the Records Custodian provide a date & hour upon which the requested information and documents will become available.

Thank you.

From: Anonymous natural person(s)

Good morning,
Pursuant to C.R.S. Section 24-72-203(3)(a), we once more ask that the Records Custodian provide a date & hour upon which the requested Materials will be made available to the Public.

Thank you.

From: Anonymous natural person(s)

To whom it may concern,

On August 5, we requested a date/time for the Materials to be made available. The reply from your Agency's legal counsel was:

"I no longer represent the Prairie View Ranch Water District."

The Agency acknowledged the CORA requests on July 6. Colorado law requires records be produced no later than 10 working days after a valid request is submitted.
Pursuant to C.R.S. Section 24-72-203(3)(a), we once more ask that the Records Custodian provide a date & hour upon which the requested Materials will be made available to the Public.

Thank you.

From: Anonymous natural person(s)

Good morning,

The Materials being requests are overdue. We insist that the Agency produce and transmit the Financial Materials within 5 working days. The Agency's records are Public property which must not be concealed, altered or destroyed.

If the Financial Materials are not transmitted by Friday Aug 27 , we will be forced to seek remedy in District Court.

Thank you.

From: Anonymous natural person(s)

Mr. Morehead,

One of the three outstanding CORA requests pending for this Agency is "Financial Records". Would you be able to assist in production and transmission of the records? The Records Custodian acknowledged the request on July 6, after we asked that the District's financial and asset information be provided within 30 days.

At this time, we would like to prioritize a subset of the full Financial Records request (see further below) to the following Materials:

1 - A complete Inventory of Assets, including bank accounts/balances, investments, deposits, raw materials, machinery, equipment, water pumps, water wells/rights, association memberships etc.
2 - A list of each of the District's 85 water taps: sale date (or indicate if unsold), sale price, and the name of the legal owner(s) of the asset.
3 - Transaction records for the 52 currently sold water taps "Plant Investment Fee" dollars collected, transferred, deposited, etc.

The District's public financial records only account for $70,855 worth of Plant Investment Fees, but 52 water taps have been sold for $15k to $30k each. Based on all available public records currently available for this Agency, we estimate that nearly $1.3 million dollars worth of Plant Investment Fees have been collected by the Agency to date. We are attempting to understand the significant discrepancy between $1.3MM and $70k and locate the remainder of the Plant Investment Fee dollars.

Documents provided by you to satisfy a previous CORA request (Elections records) suggest that more than one bank account exists. A bank account mentioned in the District's meeting minutes, provided by your Elections records response, specifically state that a new bank account was created to quote "satisfy the State". This bank account was not created until May 2018, almost 12 years after the first Plant Investment Fee was sold. Almost $500,000 worth of Investment Fees were collected between 2006 and May 2018. The current last known bank account balance of the District was $2100 (as of January 2021. We sincerely hope that you can help us locate the remainder of the Plant Investment Fee dollars that have never been reported to the CO Department of Local Govt or the Office of the State Auditor.

The original CORA request is still expected to be filled, but we would prefer to have the Inventory and water tap sales information as soon as possible. The original CORA request text pasted below.
Thank you.

Pursuant to the Colorado Open Records Act, we hereby request the following records:

Copies of any and all asset and financial records and documents belonging to, related to, received by, transmitted from, or held by Colorado Special District "Prairie View Ranch Water District, LLC" Colorado DOLA ID# 65978 ("the District") ( https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978 ) that are subject to Colorado Open Records Act (CORA). These documents and records shall be collectively referred to as "Materials". The scope of the Materials shall include all financial and asset subject matters, including but not limited to: income, revenue, expenses, taxes, Elections, real-estate, budgets, reports, records, assets, exchanges, transfers, trades funds, water tap fees, plant investment fees, Colorado Public Deposit Protection Act, payments, compensation, water distribution systems, construction and construction equipment, water rights, and the water wells having Colorado Division of Water Resources Final Permit numbers 1253-RFP, 1254-RFP and 1255-RFP.

This request shall also include Materials regarding payments and/or compensation to District Board members including Daniel Harrison, and the District's subcontractors and service providers, including the business entity known as "Harrison Homes Inc" or "Harrison Homes LLC" having CO Secretary Of State business entity ID# 20181519933.

This request shall also include any and all Materials involving asset or financial transactions with the similarly-named yet distinct business entity "Prairie View Ranch Water District LLC" having CO Secretary Of State business entity ID# 20041352078.

This request shall also include any and all Materials involving the entity(ies) "G&P Enterprises" referred to in the document "RULES and REGULATIONS FOR WATER SERVICE" with heading "Prairie View Ranch Water District LLC 2015-2016" (attached to this request for reference).

This request shall further include any and all Materials that are required by law to be submitted to the State of Colorado and/or Morgan County, such as the documents for years 2015, 2016 and 2017 that are not on file with Colorado Department of Local Affairs at https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978&category=1&jfwid=B5qt151NguWJVfzZ76NvXbwIt0QSYDI0NAAykOIr%3A0

The Produced materials shall be Transmitted in standard, searchable, sortable format whenever possible. If Materials which have been deleted can be un-deleted or otherwise recovered or restored, such as from an internet backup, court order, or subpoena, the Materials shall also be IN-scope of this request.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

As of the date of this request, the District does not have a written and published CORA Policy on file viewable to the Public in order to notify the Public in advance of the fees, therefore the District cannot charge fees for production or transmission of the requested Materials. The following URL links to a PDF document from the law offices of Seter & Vander Wall, P.C. explaining the essentials of how CORA applies to Special Districts: https://svwpc.com/wp-content/uploads/2016/08/CORA-Webinar-re-HB-14-1193-Seter-and-Vander-Wall-PC.pdf

In the unlikely case that there is a valid CORA Policy published and viewable to the Public prior to this request, we would be grateful if you would provide a total cost for the records retrieval. We would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. We look forward to receiving your response to this request within 30 days.

Sincerely,

Parties concerned with CO Public Water System ID# CO0144621

From: Anonymous natural person(s)

Mr. Morehead,

Due to the age of this request, which may predate your involvement with the Agency, we would like to clarify a specific point when it comes to the legal names named as being parties to the records ("Materials") request.

The State of CO has two distinct entities registered with nearly the same legal name:
"Prairie View Ranch Water District, LLC" - A Colorado Special District, with Department of Local Govt. ID# 65978, formed 6/12/2006.
"Prairie View Ranch Water District LLC" - A Colorado Limited Liability corporation, with CO Secretary of State ID# 20041352078, formed 10/9/2004.

Further, both of those entities are/were controlled by many of the same individuals who control "Prairie View Ranch Partners LLC", SoS ID# 20041352083, formed 10/09/2004.

The scope of all three remaining CORA requests includes any and all District-related Materials which may be in the custody of the other "Prairie View Ranch" entities.

Thank you for your assistance with this matter.

From: Prairie View Ranch Water District, Llc

TO: Parties concerned with CO Public Water System ID# CO0144621

1. I provided scanning services for the documents which you requested and I subsequently forwarded to you (and may do so again).
2. I am not an officer, employee, or director of the Prairie View Ranch Water District.

Thus I have neither the documents, lists or other transactional data that you requested and am unable to comply with your request.

I understand that the District has engaged an attorney and I am sure he will be contacting you in the near future.

Andrew T. Morehead, CFP®, ATP, ARA

360 Oak Avenue #120

Eaton, CO 80615

Phone: 970-454-2208

Fax: 970-797-1102

From: Anonymous natural person(s)

Good morning,

On August 9, the Records Custodian quoted us "a week" to copy and transmit the materials. The 7 working days have elapsed and the Materials are overdue. Pursuant to C.R.R. Section 24-72-203(3)(a), we ask for a firm date/hour upon which the Materials will be transmitted.

Thank you.

From: Anonymous natural person(s)

To Whom It May Concern:

Pursuant to the Colorado Open Records Act, we previously requested the following records on July 4 and the response from your Agency was initially promising, but has since fallen far short of the excellence that one would expect from a Colorado local government organization. We will restate our Financial Materials request once final time:

Copies of any and all asset and financial records and documents belonging to, related to, received by, transmitted from, or held by Colorado Special District "Prairie View Ranch Water District, LLC" Colorado DOLA ID# 65978 ("the District") ( https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978 ) that are subject to Colorado Open Records Act (CORA). These documents and records shall be collectively referred to as "Materials". The scope of the Materials shall include all financial and asset subject matters, including but not limited to: income, revenue, expenses, taxes, Elections, real-estate, budgets, reports, records, assets, exchanges, transfers, trades funds, water tap fees, plant investment fees, Colorado Public Deposit Protection Act, payments, compensation, water distribution systems, construction and construction equipment, water rights, and the water wells having Colorado Division of Water Resources Final Permit numbers 1253-RFP, 1254-RFP and 1255-RFP.

This request shall also include Materials regarding payments and/or compensation to District Board members including Daniel Harrison, and the District's subcontractors and service providers, including the business entity known as "Harrison Homes Inc" or "Harrison Homes LLC" having CO Secretary Of State business entity ID# 20181519933.

This request shall also include any and all Materials involving asset or financial transactions with the similarly-named yet distinct business entity "Prairie View Ranch Water District LLC" having CO Secretary Of State business entity ID# 20041352078.

This request shall also include any and all Materials involving the entity(ies) "G&P Enterprises" referred to in the document "RULES and REGULATIONS FOR WATER SERVICE" with heading "Prairie View Ranch Water District LLC 2015-2016" (attached to this request for reference).

This request shall further include any and all Materials that are required by law to be submitted to the State of Colorado and/or Morgan County, such as "Oath Of Office", Bonds, Sureties, "Application for Exemption from Audit", and the missing "Annual Budget" documents for years 2015, 2016 and 2017 that are not on file with Colorado Department of Local Affairs at https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978&category=1&jfwid=B5qt151NguWJVfzZ76NvXbwIt0QSYDI0NAAykOIr%3A0

The Produced materials shall be Transmitted in standard, searchable, sortable format whenever possible. If Materials which have been deleted can be un-deleted or otherwise recovered or restored, such as from an internet backup, court order, or subpoena, the Materials shall also be IN-scope of this request.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

We look forward to receiving your response to this request within 3 business days.

Sincerely,

Parties concerned with CO Public Water System ID# CO0144621

From: Anonymous natural person(s)

To Whom It May Concern:

Pursuant to the Colorado Open Records Act, we previously requested the following records on July 4 and the response from your Agency was initially promising, but has since fallen far short of the excellence that one would expect from a Colorado local government organization. We will restate our Financial Materials request once final time:

Copies of any and all asset and financial records and documents belonging to, related to, received by, transmitted from, or held by Colorado Special District "Prairie View Ranch Water District, LLC" Colorado DOLA ID# 65978 ("the District") ( https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978 ) that are subject to Colorado Open Records Act (CORA). These documents and records shall be collectively referred to as "Materials". The scope of the Materials shall include all financial and asset subject matters, including but not limited to: income, revenue, expenses, taxes, Elections, real-estate, budgets, reports, records, assets, exchanges, transfers, trades funds, water tap fees, plant investment fees, Colorado Public Deposit Protection Act, payments, compensation, water distribution systems, construction and construction equipment, water rights, and the water wells having Colorado Division of Water Resources Final Permit numbers 1253-RFP, 1254-RFP and 1255-RFP.

This request shall also include Materials regarding payments and/or compensation to District Board members including Daniel Harrison, and the District's subcontractors and service providers, including the business entity known as "Harrison Homes Inc" or "Harrison Homes LLC" having CO Secretary Of State business entity ID# 20181519933.

This request shall also include any and all Materials involving asset or financial transactions with the similarly-named yet distinct business entity "Prairie View Ranch Water District LLC" having CO Secretary Of State business entity ID# 20041352078.

This request shall also include any and all Materials involving the entity(ies) "G&P Enterprises" referred to in the document "RULES and REGULATIONS FOR WATER SERVICE" with heading "Prairie View Ranch Water District LLC 2015-2016" (attached to this request for reference).

We would prefer the materials be Transmitted in standard, searchable, sortable format whenever possible. If Materials which have been deleted can be un-deleted or otherwise recovered or restored, such as from an internet backup, court order, or subpoena, the Materials shall also be IN-scope of this request.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

We look forward to receiving your response to this request within 3 business days.

Sincerely,

Parties concerned with CO Public Water System ID# CO0144621

From: Anonymous natural person(s)

This request shall include all purchase contracts or other equivalent proof-of-sale/purchase for all water taps sold to date, including Lot #74.

From: Anonymous natural person(s)

We are sorry for the addendums. This request has been dragging on since July 4 and has been passed to multiple third-parties and back again. This request shall also include an "Inventory Of Assets" regarding the water delivery system and all other District assets, including bank accounts, water taps, meter readers, billing software, etc.

From: Anonymous natural person(s)

Please see attached "Water Distribution System Layout" and "Service Plan", along with Morgan County "Resolution Approving Service Plan of a Water District" for assistance with the Inventory of Assets.

From: Prairie View Ranch Water District, Llc

To whom it may concern,

This will confirm my receipt of your email. Please be advised that I am not counsel for Prairie View Ranch Water District. I am not a custodian of records for the District nor do I have any public records maintained by the District in my possession or control. I understand the current interim directors appointed by the Morgan County Commissioners are Sheila Brown. Marci McAnally, Christie Holcomb, Sam Belamonte and Jesse McCoppin.

Tim Goddard
Goddard Law Office, PLLC
210 E. 29th Street
Loveland, CO 80538
(970) 493-5070 Telephone
timg@hfglawfirm.com<mailto:timg@hfglawfirm.com> Email

From: Anonymous natural person(s)

Doryea Gibbs was the individual who acknowledged the CORA requests and stated that "six inches of paper" was in custody and would be produced. May we know how to contact the current records custodian?

From: Anonymous natural person(s)

We believe all the District's physical financial records are stored at 1001 "O" Street in the same filing cabinet as the Prairie View Ranch Owners' Association documents. Any assistance in making contact with the Custodian would be appreciated.
970-356-7090 is the current registered phone number of Colorado Special District "Prairie View Ranch Water District, LLC"
970-356-7090 is also the current phone number of the Prairie View Ranch Owners' Association
970-356-7090 is also the current phone number of the Prairie View Ranch Partners LLC
prairieviewranch@gmail.com is the current email address that is billing the District consumers
970-356-7090 is the current registered phone number of Limited Liability Corporation "Prairie View Ranch Water District LLC"
1001 "O" Street Greeley is the registered address of all entities.

From: Anonymous natural person(s)

John D. Pearson,

Pursuant to the Colorado Open Records Act, we hereby request the following records:

Copies of the Purchase Contracts, or other evidence of transactions for all water taps sold by Prairie View Ranch Water District. We estimate that 52 water tap fees have been collected by the District and would like to see a record of those transactions and where the money is deposited.

The Produced materials shall be Transmitted in standard, searchable, sortable format whenever possible.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

We look forward to receiving your response to this request within 3 business days, as required by Colorado law.
Thank you.

Thank you.

From: Anonymous natural person(s)

Daniel Harrison,

You were the President/Chair of the Prairie View Ranch Water District and took an Oath of Office (attached to this email as a reminder) to uphold the CO and US Constitutions. As President, it is your responsibility to ensure that the Treasurer is upholding their duties to the public and protecting the public's "plant investment fee" dollars. You have a legal and fiduciary responsibility to the public. Today, we expect you to carry out your sworn duty to the Prairie View Ranch Water District. Pursuant to the Colorado Open Records Act, we hereby request the following materials:

1 - All District property (keys, passwords, tools, equipment) and all Voter/Resident property under your custody or control. Physical property is to be returned to a Prairie View Ranch Water District staff member. Electronic property is to be sent via email or cloud hosting.
2 - Copies of the Purchase Contracts, or other evidence of transactions for all water taps sold by Prairie View Ranch Water District. We estimate that 52 water tap fees have been collected by the District and would like to see a record of those transactions and where the money is deposited.
3 - Any other financial records, receipts, invoices, expense reports, or other documents that are property of the District. As President, you had access to and shared custody of the District's financial assets and accounts.

https://leg.colorado.gov/sites/default/files/colorado-open-records-act-cora.pdf
If a court determines that a custodian of a public record has improperly denied the right of inspection of a public record under CORA, the court must award court costs and reasonable
attorney fees to the prevailing party. If a person willfully and knowingly violates CORA, the person commits a misdemeanor punishable by a fine of not more than $100, imprisonment
in county jail for not more than 90 days, or both.

The Produced materials shall be Transmitted in standard, searchable, sortable format whenever possible.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

We look forward to receiving your response to this request within 3 business days, as required by Colorado law.
Thank you.

  • 65978-Oath_of_Office_Partially_Complete_Filing-_Doc._ID_195703.pdf

From: Anonymous natural person(s)

Mr. Goddard,

For the last decade and several years, the District has been improperly submitting "Application For Exemption From Audit" paperwork to the Department of Local Government and and Office of the State Auditor. The District will not be allowed to exempt itself from upcoming financial audits. All of the District's financial records, and access to the accounts and assets, must be produced by the previous administration in order to carry out a third-party audit. It would be preferable for the individuals in custody of the District's financial assets and records to produce them prior to the commencement of a third-party audit. Any assistance you could provide would be appreciated, as we believe your retainer/fees are being paid by District/public funds.

Thank you.
Parties concerned with CO Public Water System ID# CO0144621

From:

1 - All District property (keys, passwords, tools, equipment)

Harrison home inc nor mr harrison holds any of the items listed above.

All Voter/Resident property under custody or control is neither held with
Mr harrison nor harrison homes.

Physical property is to be returned to a Prairie View Ranch Water District
staff members

Harrison Holmes nor mr harrison holds any physical property in association
to the water District.

Electronic property is to be sent via email or cloud hosting

Harrioson homes including Mr harrison neither holds an electronic
information on this district.

2 - Copies of the Purchase Contracts, or other evidence of transactions for
all water taps

Please see PVR water District, again Mr Harrison nor Harrison homes has any
of this information.

3 -financial records, receipts, invoices, expense reports, or other
documents that are property of the District.

Please see PVR, Mr Harrison nor Harrison homes never held any of the above
information at any time.
--
Email: Harrisondhomes@gmail.com

Cell: 970 459 7099

Local contact: Daniel Harrison

Inline images

From: Prairie View Ranch Water District, Llc

1 - All District property (keys, passwords, tools, equipment)

Harrison home inc nor mr harrison holds any of the items listed above.

All Voter/Resident property under custody or control is neither held with Mr harrison nor harrison homes.

Physical property is to be returned to a Prairie View Ranch Water District staff members

Harrison Holmes nor mr harrison holds any physical property in association to the water District.

Electronic property is to be sent via email or cloud hosting

Harrioson homes including Mr harrison neither holds an electronic information on this district.

2 - Copies of the Purchase Contracts, or other evidence of transactions for all water taps

Please see PVR water District, again Mr Harrison nor Harrison homes has any of this information.

3 -financial records, receipts, invoices, expense reports, or other documents that are property of the District.

Please see PVR, Mr Harrison nor Harrison homes never held any of the above information at any time.

From: Anonymous natural person(s)

Thank you for your reply. If you locate any stray financial documents (liability insurance policy, invoices, receipts, association/membership dues, or similar) related to the District, please upload them as standard file attachments to this email thread.

From: Anonymous natural person(s)

Thank you for your reply. If you locate any stray financial documents (liability insurance policy, invoices, receipts, association/membership dues, or similar) related to the District, please upload them as standard file attachments to this email thread.

From: Anonymous natural person(s)

Other examples of District records include membership cards, booklets, flyers, training materials, etc regarding Colorado Rural Water Association. We were able to locate a CRWA membership invoice for the District, addressed to 120 Dickson St.: https://connect.gomembers.com/pay/?key=XH62-5HZS-M8D6-8GVA
If you can help us locate any of the magazines, educational materials, CD-ROM/USB data, etc. it would be greatly appreciated.

Thank you.
Parties concerned with CO Public Water System ID# CO0144621

From: Anonymous natural person(s)

Mr. Pearson,

You were one of the individuals in charge of the Water District for the last 17 years. Do you have access to District financial records? All of the District's financial records are public property and the Public has a right to inspect them. Please produce any and all District financial records available to you at your earliest convenience.

From: Anonymous natural person(s)

Mr. Goddard,
Can you please help us retrieve the District's financial records from your client John D. Pearson? He and Fred Gibbs personally ran the Water District for the last 17 years (see Illegal Meeting Minutes PDF) and John/Doryea are still charging District water consumers' credit cards, and are still paying several un-licensed individuals to perform daily operations and chemistry regarding the Prairie View Ranch public water system. Surely John Pearson has access to District finances if he is still paying the same people to operate the system as they have been for years? All of the District's financial records and assets are public property, and the Public has a right to inspect them. How can the previous "owners" of the Prairie View Ranch Water District not understand that they are no longer in charge and were never the owners of the District's assets and never had a right to exercise any authority over the assets or proceeds from their sale?
This charade must end soon, and it would be nice if the ending could be as happy as possible and the path to the end as friction-less as possible.

Parties Concerned With Public Water System ID# CO0144621

From: Anonymous natural person(s)

The 13th Judicial District Court recommends filing a report with the Morgan County Sheriff regarding the missing financial records and assets. Prairie View Ranch Water District consumers are being charged by another for-profit business entity using the same entity name as the District.

There are two distinct legal entities in Colorado with the same legal name, minus a comma:
"Prairie View Ranch Water District, LLC" - A CO Special District ID#65978. https://dola.colorado.gov/dlg_portal/filings.jsf?id=65978
"Prairie View Ranch Water District LLC" A CO for-profit Limited Liability Corporation. https://www.sos.state.co.us/biz/BusinessEntityDetail.do?quitButtonDestination=BusinessEntityResults&nameTyp=ENT&masterFileId=20041352078

Only one of them has a right to perpetual existence and the other must relinquish its records and property to the rightful owner.

From: Anonymous natural person(s)

https://leg.colorado.gov/sites/default/files/images/olls/crs2016-title-29.pdf
The Colorado State Auditor shall take further action as prescribed by Section 29-1-606(5)(b), C.R.S.

(4) If within one month after the time period provided in subsection (1) of this section the
local government is unable to file an audit report with the state auditor, the governing body of the
local government shall submit to the state auditor a written request for extension of time to file. Such
request for extension shall be submitted no later than one month after the time period provided in
subsection (1) of this section. The state auditor may authorize an extension of such time for not more
than sixty days.
(5) (a) If the audit report of a local government is not filed with the state auditor within two
months after the time period provided in subsection (1) of this section and the local government has
not been granted an extension or exemption from the filing requirement, the state auditor shall make
written notice to the local government of its delinquent status.
(b) If the audit report of a local government is not filed with the state auditor within three
months after the time period provided in subsection (1) of this section, the state auditor shall either:
(I) Notify any county treasurer holding moneys of the local government which were
generated pursuant to the taxing authority of such local government of the delinquent audit status
of such local government and authorize such county treasurer to prohibit the release of any such
moneys until the local government submits an audit report to the state auditor; or
(II) Make or cause such audit to be made at the expense of the local government. The local
government shall reimburse the state auditor for all amounts advanced for the making of such audit,
including any legal and court costs incurred in the making of such audit.

From: Anonymous natural person(s)

Mr. Harrison,

Could you please check again for financial records regarding Prairie View Ranch Water District? You were the President of the District during the time period in which the attached checks to Harrison Homes were cut from the District's checking account. The Public would like to inspect any and all financial records pertaining to transactions between Prairie View Ranch Water District and Harrison Homes (LLC and INC), during the time period of August 2020 and October 2021.

Thank you in advance for your assistance in this matter.

From: Anonymous natural person(s)

We apologize for the extra correspondence. Can you please expand your search for documents to cover the time period of August 2019 and October 2021.

From: Prairie View Ranch Water District, Llc

Harrison Homes was contracted and does not hold detailed oriented records. e
The amounts you are referencing only apply to the work done.
Harrison Homes holds no other information as stated on 9-18-2021.
This is your second request for the same information. Unfortunately, we are
unable to provide anything more.
*Daniel Harrison*
*President of Harrison Homes, Inc. *
*(970) 459-7099*

From: Anonymous natural person(s)

If contracted, then is there a copy of the contract with the District you could provide?

From: Anonymous natural person(s)

Dear Mr. Harrison. We would like to request once again if you could please provide copies of any and all contracts between Harrison Homes (Daniel Harrison) and the Prairie View Ranch Water District LLC (Fred Gibbs, John Pearson, Doryea Gibbs (Pennington), etc). You speak of contracts between yourself and the District but also refuse to provide evidence of such contracts.

Thank you.

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