HomeMy WebLinkAbout2020CV30833 - City Of Fort Collins V. Planning Action To Transform Hughes Stadium Sustainably Corp, Et. Al - 020E - Friedman AffidavitDISTRICT COURT, CITY AND COUNTY OF
LARIMER, COLORADO
Larimer County Justice Center
201 Laporte Avenue, Suite 100
Fort Collins, Colorado 80521
(970) 498-6100
■COURT USE ONLY■
PLAINTIFF: THE CITY OF FORT COLLINS,
COLORADO, a Colorado home rule city and municipal
corporation,
VS.
Case Number: 2020CV30833
Div.: 3B
DEFENDANTS: PLANNING ACTION TO TRANSFORM
HUGHES SUSTAINABLY CORP., a Colorado nonprofit
corporation; and ELENA M. LOPEZ, MELISSA ROSAS,
AND PAUL PATTERSON, each in their official capacity as
a petition representative of the persons signing the petition
for a citizen -initiated ordinance relating to the City of Fort
Collins rezoning and acquirinE certain real property
Attorney for the Defendants:
Michael Foote, #34358
Foote Law Firm, LLC
357 S. McCaslin Blvd. Suite 200
Louisville, Colorado 80027
Phone: (303) 519-2183
Fax: (888) 804-8679
mlbfoote@gmail.com
AFFIDAVIT OF Philip H. Friedman
I, Philip H. Friedman, being duly sworn under penalty of perjury, state and declare as follows:
1. My name is Philip H. Friedman. I am over the age of 18 and I have personal knowledge
of the matters set forth in this Affidavit.
2. I am currently a resident of the City of Fort Collins and have been a resident of Fort
Collins for 43 years. I live in Council District 6.
3. While a resident of Fort Collins, I have often used the City's Natural Areas, also known
as public open lands or open space.
4. It is my opinion, and the opinion of many of my friends and acquaintances, that the City's
existing Natural Areas are one of the main positive features of living in Fort Collins.
5. I have noticed over the last several years that the Natural Areas have become more and
more crowded. As more people move to Fort Collins, more people use its Natural Areas.
The Natural Areas are suffering from wear and tear. In more colloquial terms, our
Natural Areas are being "loved to death."
6. I believe the City Council has neglected to appropriately expand acquisition and
connectivity between Natural Areas to keep up with increased use and population. The
City's current policies regarding acquisition of properties with vital connectivity need to
be reviewed. I have publicly advocated for those changes, including the expansion of the
City's existing Natural Areas and/or acquisition of new properties.
7. Since 1992, 1 have volunteered on all of the citizen lead efforts to create and expand open
space and natural areas. I have spoken on this issue before City Council numerous times.
I was a member of the City Natural Resource Advisory Board (NRAB) for
approximately 14 years, including the formative years in the early 1990s when the NRAB
had the council -directed charge to identify, review, and recommend areas for inclusion to
the city natural area system.
8. I joined Planning Action to Transform Hughes Sustainably ("PATHS") because its
leadership and other members believe — as I do — that Fort Collins needs more Natural
Areas.
9. I believe the property formerly home to the Colorado State University Hughes football
stadium would be an excellent property to acquire in an effort to obtain more open space
within Fort Collins. In addition, and critically, the Hughes property would create and
maintain a valuable connection (both ecologic and human) between Maxwell and
Pineridge Natural Areas.
10. What ultimately happens with the Hughes property will have major long-lasting effects
on Fort Collins. If the Hughes property is acquired as open space, it will allow residents
like myself and many others to enjoy the quality of life we associate with Fort Collins. If
it is developed, the City's residents will suffer a reduction in quality of life.
11. I have publicly advocated for the transformation of the Hughes property into open space
because I believe it is currently one of the best ways for the City Council to expand its
Natural Areas program and expand connectivity between natural areas.
FURTHER, Affiant sayeth naught.
STATE OF COLORADO
COUNTY OF LARIMER
Subscribed and sworn to before me this,i' day of �]Yn,, k f , 2021, by Philip H. Friedman.
JAMES A B LARSEN
NOTARY PUBLIC
STATE OF COLORADO
NOTARY ID 20104028699
MY COMMISSION EXPIRES 0S12012022
Notary public