🏡 Response to City Complaint

Official Documentation and Community Support

📞 Contact Code Enforcement Officer
Call: (719) 444-7891 Email: Michael.flynn@coloradosprings.gov

Michael Flynn, Code Enforcement Officer
Neighborhood Services Division, City of Colorado Springs

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About This Response

Case Reference: ENF25-08204

Date: December 19, 2024

Entity: The Neighbor's Pantry - Colorado Nonprofit Corporation (ID: 20258298487)

This page contains the complete documentation submitted in response to the Bear Management Area Courtesy Notice received by The Neighbor's Pantry. The submission includes the original complaint, our detailed response, extensive community feedback, photographic evidence of selective enforcement, and our official state certifications.

1. The City Complaint

The original Bear Management Area Courtesy Notice (Case ENF25-08204) issued by the City of Colorado Springs Code Enforcement Division regarding The Neighbor's Pantry's charitable food distribution operation.

Document Type: Bear Management Area Courtesy Notice
Issued By: City of Colorado Springs, Neighborhood Services Division
Pages: 3
Download City Complaint

2. Letter of Response from The Neighbor's Pantry

Our comprehensive 15-page response addressing the legal, factual, and policy issues raised by the complaint. This response demonstrates that The Neighbor's Pantry operates as a protected charitable food distribution service under state and federal law.

Key Arguments:
  • Bear Management ordinance regulates "attractant waste," not charitable food
  • State and federal law protects charitable food distribution
  • Evidence of selective enforcement
  • Complaint based on concerns about homeless populations, not wildlife
Download Response Letter

3. Community Feedback Document

An 18-page compilation of public comments and community support demonstrating the vital role The Neighbor's Pantry plays in addressing food insecurity in Northwest Colorado Springs. This document includes testimonials from neighbors, community members, and those who have benefited from the pantry's services.

Community Impact: These comments showcase the overwhelming support for The Neighbor's Pantry's mission and the positive impact it has had on the Rockrimmon community. The feedback demonstrates that this is a valued community resource serving a critical need.
Download Community Feedback

4. Bear Ordinance Violation Pictures

Photographic documentation (18 pages) of actual bear attractant violations observed along the code enforcement officer's route to The Neighbor's Pantry. This evidence demonstrates selective enforcement, as multiple clear violations of the Bear Management ordinance were not addressed while our charitable food distribution was targeted.

Evidence of Selective Enforcement: These photographs document unsecured trash cans, accessible garbage, and other actual bear attractants that remain unaddressed despite being in plain view along the same route used by the code enforcement officer. This raises serious questions about the fairness and consistency of enforcement actions.
Download Violation Pictures

5. Official State Certifications

Official documentation from the Colorado Secretary of State confirming The Neighbor's Pantry's status as a registered nonprofit corporation in good standing with the State of Colorado.

📜 Certificate of Good Standing

Official certificate confirming The Neighbor's Pantry is a nonprofit corporation in good standing with the Colorado Secretary of State.

Entity ID: 20258298487
Formation Date: November 24, 2025

Download Certificate

📋 Articles of Incorporation

The official Articles of Incorporation filed with the Colorado Secretary of State, establishing The Neighbor's Pantry as a nonprofit corporation.

Filed: November 27, 2025
Status: Active and In Good Standing

Download Articles

📋 Summary of Submission

This comprehensive submission responds to the Bear Management Area Courtesy Notice and demonstrates that:

  • The Bear Management ordinance regulates "attractant waste," not charitable food distribution
  • State and federal law explicitly protects charitable food distribution activities
  • Enforcement appears selective and potentially discriminatory
  • Multiple actual bear attractant violations exist along the inspector's route
  • The original complaint was based on concerns about homeless populations, not wildlife management
  • Extensive community support exists for The Neighbor's Pantry's mission
  • The Neighbor's Pantry is a registered Colorado nonprofit corporation in good standing

The Neighbor's Pantry seeks a cooperative resolution that respects both wildlife management objectives and our charitable mission to serve food-insecure neighbors with dignity and respect.

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