(5).

That each of thc dcfendants, in performing the acts and or omissions

described above and elsewhere in this complaint, performed said aet~ and or omissions in the
furthenmce of a civil, and or, criminal conspiracy, or common enterprise, which was the legal
and proximate cause of injury and damages suffered by plaintiff.
6). That each of the defendants committed a civil conspiracy in violation of
"COCCA" that: (I) two or more persons; (2) come to a meeting of the minds; (3) on an object to
bc accomplished or a course of action to be followed; (4) and one or more overt unlawful act~ are
performed; (5) with damages a~ the proximate result thereof. See; .jet Courier Service, Inc. v.
Mulei, "Z7l P.2d 486 (Colo. 1989).
159. Section 18-17-107, used in the civil context, is remedial and not penal in nature.
Thus, statute of limitation for bringing an action under that section may be tolled until the time of
rea~onahle discovery of injurious act a~ provided by ~ 13-80-101. Todd JIolding Co. v. Super
Valu Stores, 874 P.2d 402 (Colo.App.1993).
160. As a n.-sult of said acts and or omissions, plaintiff is entitled to threefold the
actual damages, compensatory, and or punitive damages, equitable relief, injunctive relicI',
and the reasonable costs, fees, and expenditures, normally referred to as allorney fees, borne
by a pro sc litigant in the prosecution of a civil action, and intcrest both pre and post trial.

Wherefore, plaintiff prays for judgment against all defendant~ by reason of their
involvement in an ongoing criminal and civil conspimcy , that being in violation of Colorado
Law;
The statute prohibits a defendant from engaging in, or benefiting from, a "pattern of racketeering
activity." People \' Chaussee, 880 P.2d 749 «'010.1..294), and their guilt as to one or all of the
counts alleged in this complaint, their actions being against the peace and dignity of the People of
the State of Colorado and this plaintiff, and against the laws of this State as well, plaintiff is
entitled to compensatory damages, actual damages, punitive damages, injunctive relief, and the
costs involved in bringing this action which inelude plaintiff.~ time and money as a pro se litigant,
normally referred to as Attorney's fees, pre trial and post trial interest in accordance with the
C.R.S., and any other relief that the Court deems appropriate, necessary, and equitable in this
mailer.

Respectfully Submittcd,

Dany L. Clementson" Plaintiff pro sc.

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