Plaintiff seeks enforcement of the Taxpayer’s Bill of Rights of the Colorado
Constitution (“TABOR”).  TABOR requires a vote of the people
before the State or any local government may: create new debt, levy new taxes, increase tax
rates, or institute tax policy changes directly causing a net tax revenue gain. Id. Without a vote
of the people, the Colorado Bridge Enterprise has created new debt, levied new taxes, increased
tax rates, and instituted tax policy changes causing a net tax revenue gain to the Colorado
Department of Transportation and the Bridge Enterprise. By taking these actions without a vote
of the people, Defendants have violated the rights of Plaintiff’s members to vote on the
imposition of new taxes and debt, as guaranteed by TABOR. Plaintiff therefore seeks
declaratory and injunctive relief to abate and correct Defendants’ unconstitutional actions.

Supplemental Appendix Final