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14-cv-02850-REB-KLM
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In response to Paragraph 8 of the Complaint, Ethics Watch admits and avers that
this Court has jurisdiction over the subject matter of this action.
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In response to Paragraph 9 of the Complaint, Ethics Watch admits and avers that
this Court has jurisdiction over the subject matter of this action.
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In response to Paragraph 13, Ethics Watch admits that CCL is a Colorado nonprofit corporation. Ethics Watch is without information sufficient to form a belief as to
the remaining factual allegations of Paragraph 15 and therefore denies them. The
remainder of Paragraph 15 contains legal conclusions, legal argument, or describes
the relief sought. Because these are not factual allegations, no response is required.
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Ethics Watch denies the allegations of Paragraph 42 of the Complaint and further
avers that (1) the original hearing date of September 23, 2014 was continued upon a
motion made by RMGO and CCL, and (2) Ethics Watch did not oppose RMGO and
CCLs motion for a second continuance of the hearing to December 17, 2014 at 9:00
a.m.
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with the State of Colorado. Ethics Watch denies the remaining allegations of
Paragraph 43 of the Complaint.
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In response to Paragraph 46, Ethics Watch admits and avers that RMGO is
subject to fines for their violations of Colorado disclosure laws, and that Ethics
Watch urged RMGO and CCL to comply with Colorado law as reflected in Exhibit H.
Ethics Watch denies the remaining allegations of Paragraph 46.
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In response to Paragraph 77, Ethics Watch admits and avers that it urged RMGO
and CCL to comply with Colorado law as set forth in Exhibit H. The remainder of
Paragraph 77 states legal conclusions and argument that do not require a response.
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Paragraph 84 of the Complaint states legal conclusions and argument that do not
require a response.
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Ethics Watch denies the allegations of Paragraph 85 of the Complaint and further
alleges that the Colorado Constitution was amended in 2002, among other things, to
require disclosure of political spending.
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Plaintiffs have failed to state a claim upon which relief could be granted against
Ethics Watch.
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CERTIFICATE OF SERVICE
I certify that on December 15, 2014, a copy of the foregoing ANSWER OF
CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON D/B/A
COLORADO ETHICS WATCH was served through CM/ECF on the parties listed below:
David A. Warrington
Laurin H. Mills
Andrew J. Narod
Paris R. Sorrell
LeClairRyan, A Professional Corporation
2318 Mill Road, Suite 1100
Alexandria, Virginia 22314
Telephone: (703) 684-8007
Facsimile: (703) 647-5999
david.warrington@leclairryan.com
laurin.mills@leclairryan.com
andrew.narod@leclairryan.com
paris.sorrell@leclairryan.com
James O. Bardwell
Rocky Mountain Gun Owners
501 Main Street, Suite 200
Windsor, CO 80550
Telephone: (877) 405-4570
Facsimile: (202) 351-0528
jb@nagrhq.org
Attorneys for Rocky Mountain Gun Owners and Colorado Campaign for Life
KATHRYN A. STARNELLA*
Assistant Attorney General
FREDERICK R. YARGER*
Assistant Solicitor General
Public Officials Unit |State Services Section
1300 Broadway, 10th Floor
Denver, Colorado 80203
Telephone: (720) 508-6176
Facsimile: (720) 508-6041
E-Mail: kathryn.starnella@state.co.us
fred.yarger@state.co.us
Attorneys for Colorado Secretary of State
___s/ Luis A. Toro_________________
Luis A. Toro
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