MCALLISTER, DARNELL &

GOTTLIEB, P.C.
The Cannabis Law Center
Denver Office
36 Steele Street, Suite 200
Denver, CO 80206
(Ph) 303-226-6252
(Fax) 720-542-8391
Summit County Office
111 S. Main St., #C11 (FedEx/UPS Address)
PO Box 3903 (US Post Office Address)
Breckenridge, CO 80424
(Ph) 970-453-6594
(Fax) 970-453-6877

______________________________________________
INITIAL FAX TRANSMISSION WITH U.S. MAIL TO FOLLOW

February 17, 2011

Defendant Mickey Zeppelin

Zeppelin Development
3455 Ringsby Court, Suite 100
Denver , CO 80216

Defendant Judy Montero

3457 Ringsby Court
Denver, CO 80216

David Fine
Denver City Attorney
1437 Bannock, St., Room 353
Denver, CO 80202
Fax: (720) 865-8796

Susan Barnes-Gelt
861 Humboldt St, Apt C
Denver, CO 80218

Re: NOTICE OF LAWSUIT PURSUANT TO § 24-10-109, C.R.S.

1
Dear Addressees:

Please construe this letter as notice of lawsuit pursuant to C.R.S. § 24-10-109. I look
forward to receiving your response within 90 days as provided by C.R.S. § 24-10-109(6) as to
whether you accept or deny this claim in whole or in part.

Name and Address of Claimants/Plaintiffs :

Dan Emmans

Name and Address of Claimants’ Attorney :

Sean T. McAllister, Esq.

McAllister, Darnell & Gottlieb, P.C.
The Cannabis Law Center, P.C.
Denver Office
36 Steele Street, Suite 200
Denver, CO 80206
(Ph) 303-575-5600
(Fax) 720-542-8391
Summit County Office
111 S. Main St., #C11 (FedEx/UPS Address)
PO Box 3903 (US Post Office Address)
Breckenridge, CO 80424
(Ph) 970-453-6594
(Cell) 970-393-3164
(Fax) 970-453-6877
(Em) sean@cannabislawcenter.com
www.cannabislawcenter.com

Factual Basis of Claim:

See attached complaint entitled “Complaint Seeking Injunction and Damages” for factual
allegations.

The government’s actions have caused significant injury to Plaintiffs that demands
redress.

Name and Address of Any Public Employee Involved, if Known

On information and belief, Denver City Councilwoman Judy Montero is responsible for
some damages to Plaintiffs along with the other named Defendants in the attached draft
complaint. Claimants assert claims against this public official and any others currently unknown
to the claimants who may be involved in this matter.

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Nature and Extent of Injury Claimed to Have Been Suffered and Amount of Damages
Requested

As explained in the attached draft complaint, Mr. Emmans and his company have
invested over $1,000,000 in their business. Defendants’ actions have jeopardized that investment.
In addition, Defendants’ actions have made it unlikely the subleasees will renew their leases,
creating likely damages of over $40,000 per month until and if new subrenters can be found.
Defendants’ actions have also cause damages for the public disclosure of private facts in an
amount to be proven at trial.

In sum, Mr. Emmans request a minimum of $1,500,000 in monetary damages at this time.
This is a conservative amount designed to spare the government the resources and time that
would be spent on litigation. This figure does not include many other collateral costs of this
case, such as the impact to medical marijuana patients. The Plaintiff reserves the right to request
the full amount of their damages in the event this claim is denied in whole or in part.

Thank you for your consideration of this claim. If you need any further information,
please do not hesitate to contact me at the address, phone, or electronic mail above. I look
forward to hearing from you within the statutory period for response.

Sincerely,

Sean T. McAllister, Esq.

cc: Dan Emmans