COUNTY OF COCONINO DOEGE DEVELOPMENT LLC, an Arizona ) Case No. limited liability company, ) Plaintiff, ; COMPLAINT VS. ) )
CPH 642 RT 66 LLC, a Delaware limited liability ) company; BSP ODF I ATLAS SELLER, LLC, a ) Delaware limited liability company; BSP ODF II ) FINANCE, LLC, a Delaware limited liability ) company; CTZNS INC., an Arizona corporation, ) doing business as THAT 1 PAINTER PHOENIX; ) KAT CONSTRUCTION SERVICES INC.,an ) Arizona corporation; PACIFIC DECORATIVE ) CONCRETE, INC., a California corporation; ) JOHN DOE and JANE DOE I-1V; ABC ) CORPORATIONS I-IV; and BLACK AND ) WHITE PARTNERSHIPS I-IV, )
Defendants.
For its Complaint against the above-named defendants, plaintiff Doege Development LLC (“Doege”) alleges as follows: JURISDICTION AND VENUE 1. This lawsuit involves the construction of a project commonly known as the Trailborn Williams Hotel project (“the Project™).
2. The Project was constructed on certain real property located in Coconino County, Arizona described specifically in Exhibit A (“the Subject Property™).
3. On June 26, 2025, Doege recorded a mechanics’ and materialmen’s lien (“the Lien”) against the Subject Property. The Lien was recorded at record no. 4019685 in the official records of Coconino County, Arizona. A true and correct copy of the Lien as recorded is attached hereto as Exhibit B and incorporated herein by reference.
4, Defendants have caused events to occur in Coconino County, Arizona, out of which the claims that are the subject of this Complaint arose. In addition, the Lien that is the subject of Doege’s Third Claim for Relief is upon land situated in Coconino County, Arizona. Venue is therefore proper in Coconino County, Arizona.
DOEGE-DEVELOPMENT-LLC-an-Arizona-VS.-CPH-642-RT-66-LL
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