NINETEENTH JUDICIAL DISTRICT COURT PARISH OF EAST BATON ROUGE STATE OF LOUISIANA LRK, L.L.C.
SUIT NUMBER:
_________________
DIVISION:
_________________
VERSUS THE CITY OF ST. GEORGE, CHRIS RIALS, AND NORMAN BROWNING PETITION FOR DECLARATORY JUDGMENT AND DAMAGES The petition of LRK, L.L.C. (“LRK”), a Louisiana limited liability company, with respect represents: 1. Made defendants herein are: (a) the City of St. George, a putative Louisiana municipal entity (“St. George”), (b) Chris Rials, in his capacity as Vice-Chairman of the Petition to Incorporate St. George (“Rials”), and (c) Norman Browning, in his capacity as Chairman of the Petition to Incorporate St. George (“Browning”) (collectively, “Defendants”). 2. LRK owns the following described property situated in East Baton Rouge Parish on Pecue Lane at its intersection with Interstate 10 (the “LRK Tract”), to wit: A portion of the Leon R. Kleinpeter, Sr. Estate, being a 26.7325 acre parcel of land known as Parcel 9-3 of Lot 9, a 12.7944 acre parcel of land known as Parcel 8-2 of Lot 8, and a 19.1839 acre parcel of land known as Parcel 8-3 of Lot 8, being portions of the Leon R. Kleinpeter, Sr. Estate, as shown on a map made by Carl L. Mistric, entitled "Map Showing Survey of a Portion of The Leon R. Kleinpeter, Sr. Estate containing a total of 356.1796 acres, being Lots J, 4, 8 & 9 of the Old Hiram Mansur Estate, and 29.4149 acres of the Old Buck smith Tract being called Lot "X", located in Section 49, T8S-R2E, Greensburg Land District, East Baton Rouge Parish, Louisiana. THE HISTORY OF THE LRK TRACT 3. LRK, its predecessor, LRK, a Partnership in Commendam and the ancestors of the current members of LRK, have been the owners of the LRK Tract for over 100 years, predating both the adoption of the home rule charter for East Baton Rouge Parish in 1948 and the most recent incorporation efforts of St. George. 4. The Parish of East Baton Rouge first adopted a comprehensive zoning ordinance in 1950.
-1-