"Triangle Land Conservancy, TLC, has filed a complaint in Orange County Superior Court to force Union Grove Farm to comply with the terms of a conservation easement put in place in perpetuity by the former owners of what was then called Maple View Farm. TLC has held a Conservation Easement over a portion of the property since 1995 for the express purpose of “forever conserving the open space character, agricultural productivity and scenic qualities” of the property.

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Specifically, TLC’s lawsuit asks the Court to order remediation of the prohibited roads and declare that the 2,500-seat amphitheater is an easement violation. TLC also asks the court to require the defendants to restore the property to its condition before the roads were built and to enjoin development of the amphitheater in the future."

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TLC notes in the complaint that UGF built 3 unapproved roads between 2023 - 2025, and UGF has denied that these roads are a violation of the conservation easement.  According to the complaint, "Under the terms of the Conservation Easement, Defendants are obligated to restore the Conservation Property and repair the damage caused by its actions"​​​

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Below are the full Complaint, and Exhibit I from the Complaint, which is a TLC letter to Orange County regarding UGF's use of the agritourism definition.  It's an interesting read.

Scroll to Page 19 for the beginning of the Factual Background details.