Cotton, Christopher v. Scholle, William Bryce

At all times relevant, Ms. Scholle owned, and continues to own, agricultural land

in Routt County located at 32605 County Road 35, Steamboat Springs, CO 80487.

That agricultural land is surrounded by a fence.

Inside that agricultural land is a dwelling located at 32557 County Road 35,

Steamboat Springs, CO 80487, which was also owned by Ms. Scholle at all times relevant.

To see the dwelling, one must drive through the gate at 32557 County Road 35 and

up and over a hill. In other words, the dwelling is not visible to persons driving on County Road

35, including law enforcement.

On January 29, 2022, Ms. Scholle was inside her dwelling getting prepared to watch

a movie with her daughter.

Her husband was downstairs getting ready to enter the hot tub on the backyard patio

of the dwelling with her other daughter.

Suddenly, abruptly, without warning, and without Ms. Scholle’s authorization,

Intervenor-Defendant drove onto Ms. Scholle’s agricultural land, up the hill, down the side of Ms.

Scholle’s dwelling, and into the backyard of Ms. Scholle’s dwelling.

Causes of Action

FACTS COMMON TO ALL CAUSES OF ACTION