District Court, Garfield County, Colorado Court Address: 109 8th St., Ste.

104 Glenwood Springs, CO 81601 In re Matter of: Plaintiff: Alvaro Agon 302 Meadowood Drive, #G1 Carbondale, CO 81623 and Defendants: Colorado Immigrant Rights Coalition Statutory Agent, Julian Ross 2525 W. Alameda Blvd. Ste. 300 Denver, CO 80219 and Brendan Greene 2525 W. Alameda Blvd. Ste 300 Denver, CO 80219

EFILED Document CO Garfield County District Court 9th JD Filing Date: Oct 19 2011 2:38PM MDT Filing ID: 40448373 Review Clerk: Nola Buchanan

COURT USE ONLY

Attorney for the Petitioner: Tom Adgate 2070 CR 109, Glenwood Springs, CO 81601 Phone Number: 970-456-6148 E-mail: tadgate1027@msn.com FAX Number: 970-947-1086 Atty. Reg. #: 39630

Case Number:

11CV____
Division Courtroom

COMPLAINT

COMES NOW, Alvaro Agon, by and through his attorney, Tom Adgate, and states the following: 1. Alvaro Agon, a citizen of the United States, and who, at all relevant times, resided in Carbondale, Colorado, County of Garfield. Alvaro Agon is employed as a police officer for the Town of Carbondale whose duties are primarily, but not limited to, School Resource Officer. 2. Colorado Immigrant Rights Coalition, hereafter referred to as CIRC, is a Colorado nonprofit corporation. CIRC is currently out of compliance with the Colorado Secretary of State. 3. Julian Ross is the Statutory Agent of the Corporation.
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4. The stated purpose of the corporation is to build a unified statewide voice to defend and advance justice for all immigrants and refugees in Colorado and the United States. 5. Brendan Greene is an employee/agent of CIRC doing business in Garfield County, Colorado 6. At all relevant times, Greene was either acting on behalf of CIRC, or he acted in his personal capacity, to publish and disseminate to the media and others, false statements concerning Plaintiff Alvaro Agon. COUNT I On or about Sept. 19, 2011, in or about the County of Garfield, Colorado, Defendants CIRC and Brendan Greene published to the media, Officer Agons employer, and many others in the community, a list of complaints and allegations against Officer Agon detailing false allegations about him. Brendan Greene continued to repeat these defamatory statements to the media. In their press release and statements on TV and radio, CIRC and Brendan Greene demanded Alvaro Agon be removed as School Resource Officer (SRO) and that he be immediately suspended from his duties until an investigation is completed. CIRC and Brendan Greene knew or should have known that the defamatory statements about Officer Agon were false. CIRC and Greene failed to investigate the truthfulness of the statements and the motivation of their witnesses. As a result of the Defendants negligence, and or maliciousness, Officer Agon was defamed, and as a proximate cause of the Defendants acts, his reputation in the community was severely damaged. Officer Agon has also suffered severe mental distress as a result of the false allegations of the Defendants. In addition to his damaged reputation, the Plaintiff has suffered special damages in the form of medical expenses, loss of income, and the loss of future earnings. WHEREFORE, as a result of the defamatory statements and negligence of the Defendants CIRC and Brendan Greene, Officer Alvaro Agon requests he be awarded damages for the injury to his reputation, and special damages that legally flow from the Defendants falsehoods. Plaintiff also requests the Court award attorneys fees and costs. Plaintiff submits a demand for a jury to decide these issues. Respectfully submitted,

Date: Oct. 19, 2011 Tom Adgate, #39630 Attorney for the Plaintiff
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This document is being e-filed, pursuant to C.R.C.P. 121, 1-29(9). A signed original will be maintained by the filing partys office and made available to the Court and opposing counsel upon request.

Certificate of Mailing I hereby certify that I have on this 19th day of October 2011, served a true and correct copy of the above and foregoing Complaint and District Court Cover Sheet, to the person(s) designated below by placing same in the U.S. Mail, certified mail and addressed as follows: Colorado Immigrant Rights Coalition Julian Ross, Statutory Agent 2525 W. Alameda Blvd. Ste. 300 Denver, CO 81219 Brendan Greene 2525 W. Alameda Blvd., Ste. 300 Denver, Co 81219

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