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Case 2019CV000128 Document 1 Filed 08-12-2019 Page 3 of 20 <br /> FILED <br /> 08-12-2019 <br /> Burnett County <br /> STATE OF WISCONSIN CIRCUIT COURT BURNET-fM19 W <br /> 2019CV000128 <br /> CONCERNED CITIZENS OF <br /> BIG WOOD LAKE, U.A., <br /> 22592 Assembly Drive <br /> Grantsburg,Wisconsin 54840 <br /> Plaintiff, <br /> V. Case No. 19-CV- <br /> (Case Code 30701) <br /> WOOD LAKE CAMP &RV, LLC Declaratory Judgment <br /> n/k/a Wood Lake Camp &Resort, LLC <br /> 11717 Pine Lake Road <br /> Fredrick, Wisconsin 54837 <br /> Defendant. <br /> COMPLAINT <br /> Now comes CONCERNED CITIZENS OF BIG WOOD LAKE, U.A. ("CCoBWL") and <br /> for its complaint against Defendant WOOD LAKE CAMP&RV, LLC ("WLCRV"), states and <br /> alleges as follows: <br /> NATURE OF ACTION <br /> 1. Plaintiff property owners association seeks declaratory and injunctive relief <br /> against Defendant regarding Defendant's ongoing and imminent and improper non-conforming <br /> use of a 234-acre property located adjacent to Big Wood Lake in the Towns of Wood River and <br /> Trade Lake in Burnett County. Defendant Wood Lake Camp &RV, LLC (hereinafter <br /> "WLCRV") is attempting to use its property without obtaining necessary permits and contrary to <br /> applicable zoning. WLCRV is asserting that it is continuing the operation of a former religious <br /> Bible camp that owned and operated the property for many years. It is not. The former Bible <br /> Camp closed in early 2018 (the "Camp property"). And it stopped serving youth and family <br /> campers in the summer of 2017. The last organized activity at the property was in January 2018 <br /> 3 <br />