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October 22, 2013

Hon. Scott GesslerColorado Secretary of State

c/o Mr. Richard Coolidge, Public Information Officer

VIA EMAIL TOrichard.coolidge@sos.state.co.us

RE: Colorado Open Records Act Request

Dear Mr. Secretary:

Pursuant to the Colorado Open Records Act, C.R.S. 24-72-201 et seq., Colorado Ethics

Watch (Ethics Watch) makes this request of you for records, regardless of format, medium orphysical characteristics.

Specifically, Ethics Watch seeks to inspect the following documents and records from

you as custodian of records for the Colorado Department of State:

1. Budget tracking documents, billing reports from the Department of Law that

show the amounts charged by the Department of Law or any outside counsel to the

Department of State budget in connection with the following litigation matters from their

inception through the date of your response to this request:

a. Mari lyn Marks v. Scott Gessler, et al., Denver District Court Case No.

2011CV5101 and Colorado Court of Appeals Case No. 12CA0549;

b. Citizen Center v. Scott Gessler, et al., United States District Court,

District of Colorado Case No. 12-cv-00370-CMA-MJW and United States Court of Appeals

for the Tenth Circuit Case No. 12-0414; and

c. L ibertar ian Party of Colorado, et al . v. Scott Gessler, et al, Denver

District Court Case No. 2013CV033491; Gil bert Or tiz, et al. v. L ibertar ian Par ty of Colorado,

et al., Colorado Supreme Court Case No. 2013SA206, and Scott Gessler v. Gilbert Ortiz,

Colorado Supreme Court Case No. 2013SA223.Please note that we are looking for

documents regarding litigation billings and expenses, not confidential attorney-client

correspondence or work product. If you claim litigation budget or billing reports or other

responsive documents contain privileged material, please contact me to discuss how toproceed.

2. Budget tracking documents, time sheets or any other records of time spent

and expenses incurred by Department of State personnel responding to open records

requests filed by Marilyn Marks, Mary Eberle, Margit Johannson or Citizen Center during

2013 only.

mailto:richard.coolidge@sos.state.co.usmailto:richard.coolidge@sos.state.co.usmailto:richard.coolidge@sos.state.co.usmailto:richard.coolidge@sos.state.co.us

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Ethics Watch requests that you transmit the requested documents by electronic mail

consistent with C.R.S. 24-72-205(1)(b). Ethics Watch does not agree to pay any charges

associated with the retrieval of responsive documents without prior authorization. No additionalfees may be charged for transmitting records via electronic mail under C.R.S. 24-72-205(1)(b).

If you deny access to any of the above public records, please provide forthwith a writtenstatement of the grounds for the denial, citing the law or regulation under which access is denied

as required by C.R.S. 24-72-204(4).

If you have any questions about this request or foresee any problems in transmitting fully

the requested records, please call me. I can be reached at (303) 626-2100. You can deliver therequested documents to me by electronic mail at ltoro@coloradoforethics.org.

Thank you for your prompt attention to this request.

Sincerely,

Luis Toro

Director