On December 23, 2024, Plaintiffs Mary Sekowski and Teller County Short-Term Rental
Alliance filed a Complaint for Declaratory and Injunctive Relief and Jury Demand in the
District Court, Teller County, State of Colorado, against the City of Woodland Park. The
lawsuit seeks to invalidate Ordinance 1469.
The City intends to defend the lawsuit vigorously and, like the earlier lawsuit filed on this
issue, believes the Plaintiffs’ Complaint is without merit.
Andrew D. Ringel, Esq. of Hall & Evans, L.L.C., has been retained to represent the City in
the lawsuit.
Today, Mr. Ringel filed a Stipulation Concerning the Enforcement of Ordinance 1469 Until
the Motion for Preliminary Injunction is Decided. A copy of the Stipulation is attached. As
the Stipulation itself explains, the purpose of the Stipulation is to allow the parties to
appropriately brief the Plaintiffs’ Motion for Preliminary Injunction and for the District
Court to have sufficient time to consider the issues raised by the Plaintiffs’ Complaint in
an orderly and appropriate fashion. Mr. Ringel decided to file the Stipulation because of
his belief doing so was appropriate to allow him to prepare and file a Motion to Dismiss
Plaintiffs’ Complaint and a Response to the Plaintiffs’ Motion for Preliminary Injunction for
consideration by the District Court.
Because the Plaintiffs’ Complaint and Motion for Preliminary Injunction were filed right before the holidays, Mr. Ringel has not had sufficient time to prepare the appropriate submissions to the District Court. In the absence of the Stipulation, the District Court could decide the issues raised by the Plaintiffs without benefiting from the City’s submissions, a prospect Mr. Ringel believes was not an appropriate risk.
Mr. Ringel did not file the Stipulation as an acquiescence to any of the arguments or
demands for the Plaintiffs’ relief. Instead, Mr. Ringel filed the Stipulation to allow
sufficient time for him to prepare comprehensive responses to demonstrate to the District
Court that the Plaintiffs’ Complaint fails to state any viable claim and there is no basis for
the District Court to enter any preliminary injunction.
The City respects the will of the voters who passed Ordinance 1469 and intends to contest
all aspects of the Plaintiffs’ claims and requests for relief during the litigation. Mr. Ringel
filed the Stipulation as a tactical and strategic decision to accomplish this overall goal.
STIPULATION CONCERNING ENFORCEMENT OF ORDINANCE 1469 UNTIL
MOTION FOR PRELIMINARY INJUNCTION IS DECIDED
Defendant City of Woodland Park, by and through its counsel, Andrew D. Ringel, Esq., of
Hall & Evans, L.L.C., hereby respectfully submits this Stipulation Concerning Enforcement of Ordinance 1469 Until Motion for Preliminary Injunction is Decided, as follows:
1. Plaintiffs filed their Complaint for Declaratory and Injunctive Relief and Jury
Demand (“Complaint”) on December 23, 2024. Plaintiffs’ Complaint challenges Ordinance 1469, a citizen initiated Ordinance that went into effect on December 12, 2023.
2. On December 24, 2024, Plaintiffs filed an Unopposed Motion to Exceed the Page
Limit for Motion for Preliminary Injunction and a Motion for Preliminary Injunction. On
December 27, 2024, this Court denied Plaintiffs’ Unopposed Motion to Exceed the Page Limit for Motion for Preliminary Injunction. This Court also on December 27, 2024, denied Plaintiffs’ Motion for Preliminary Injunction but indicated it could be refiled within the applicable page limitation.
3. On December 31, 2024, Plaintiffs refiled their Motion for Preliminary Injunction
with this Court.
4. Section 5 of Ordinance 1469 takes effect on December 31, 2024.
5. To allow the parties to appropriately brief the Plaintiffs’ Motion for Preliminary
Injunction and for this Court to have sufficient time to consider the issues raised in this matter in an orderly and appropriate fashion, the City of Woodland Park files this Stipulation Concerning Enforcement of Ordinance 1469 Until Motion for Preliminary Injunction is Decided. The City agrees not to enforce Section 5 of Ordinance 1469 until this Court rules on the Plaintiffs’ Motion for Preliminary Injunction. The City files this Stipulation Concerning Enforcement of Ordinance 1469 not because it believes Plaintiffs’ claims have merit, but to allow an orderly and appropriate consideration of this matter by the parties and this Court.
6. Counsel for the Defendant intends to respond to the Plaintiffs’ Complaint and the
Plaintiffs’ anticipated re-filed Motion for Preliminary Injunction as soon as practicable. Counsel for the Defendant believes a hearing before this Court on the Plaintiffs’ Motion for Preliminary Injunction would be appropriately scheduled for the second or third week in January 2025 and suggests counsel for the parties set this matter for a hearing on a mutually agreeable date for the parties, their counsel, and this Court.
WHEREFORE, Defendant City of Woodland Park respectfully submits the foregoing
Stipulation Concerning Enforcement of Ordinance 1469 Until Motion for Preliminary Injunction
is Decided.
Dated this 31st day of December, 2024.
Respectfully submitted,
/s/ Andrew D. Ringel________________
Andrew D. Ringel
HALL & EVANS, LLC
1001 17th Street, Suite 300
Denver, Colorado 8202
(303)628-3300
ringela@hallevans.com
ATTORNEY FOR DEFENDANT
