SURREPLY IN OPPOSITION TO DEFENDANT'S MOTION TO DISMISS

DISTRICT COURT, PITKIN COUNTY, COLORADO

Pitkin County Courthouse

506 E. Main, Suite 300

Aspen, Colorado 81611

Plaintiff(s):

MARILYN MARKS

v.

Defendant(s):

KATHRYN KOCH

? COURT USE ONLY ?

Attorney for Plaintiff: Case Number: 2009CV294

Robert A. McGuire

Robert A. McGuire, Attorney at Law, LLC

1624 Market Street, Suite 202

Denver, Colorado 80202

Phone Number: 303-734-7175 Div.: 3 Ctrm.:

FAX Number: 303-734-7166

E-mail: ram@lawram.com

Atty. Reg. #: 37134

SURREPLY IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS

Plaintiff Marilyn Marks, by and through her undersigned counsel, respectfully submits

this Surreply in Opposition to Defendant’s Motion to Dismiss in order to respond to incorrect

statements, new factual references and new legal arguments made and raised for the first time by

the Defendant in the Defendant’s Reply Memorandum in Support of Motion to Dismiss (the

“Reply”).

 

I. The Court should disregard the Defendant’s mischaracterizations of the Plaintiff’s

statements and legal arguments.

 

In the Reply, the Defendant incorrectly attributes to the Plaintiff statements and positions

that the Plaintiff has not made and does not hold, and which are not evidenced by either the

pleadings or the record.

 

First, on page 2 of the Reply, the Defendant states: “…the Plaintiff acknowledges that

much of Plaintiff’s factual allegations contained in her Complaint are immaterial to the issues in

the case at bar…” The Plaintiff has in fact nowhere expressly or impliedly made any such

concession, and she cannot do so because all of the averments of fact set out in the Verified

Complaint and Application for Order Directing Custodian to Show Cause (the “Verified

Complaint”) are material to the Plaintiff’s claim under Section 24-72-204(5), C.R.S.

 

Second, on page 15 of the Reply, the Defendant states: “…Plaintiff acknowledges here

that certain ballots have identifying information in the form of write-in votes.” The Plaintiff

has in fact never agreed that write-in votes constitute identifying information. The Plaintiff

twice (on July 20 and September 15) offered to narrow her CORA request in an attempt to

address the Defendant’s stated concerns about identifiable information on the TIFF files,

(V. Compl. ¶ 55), but in doing so she never conceded that the Defendant was correct in arguing

that ballots containing write-in votes are personally identifiable.

 

Third, on page 17, in footnote 6, the Defendant alludes to “the Plaintiff’s continuing

claims of an unconstitutional election….” The Plaintiff has made no such claims on the record

in this litigation. Any questions about the constitutionality of Aspen’s May 9, 2009, election

would in any event be irrelevant to the CORA question before the Court, except insofar as the

existence of public controversy would serve as evidence to suggest that the public interest would

benefit from, rather than be harmed by, the additional transparency that allowing public

inspection of the TIFF files would provide.

 

Fourth, on page 18, the Defendant states: “Plaintiff points out that if some voters at the

last municipal election marked their ballots in such a way that makes those ballots personally

identifiable, they voted illegally”; and, fifth, on page 19, the Defendant disingenuously attributes

to the Plaintiff the view that, “all ballots with distinguishing marks are to be considered as illegal

ballots and not counted.”

 

The Plaintiff has not argued in favor of the position incorrectly attributed to her by the

Defendant in these two statements. The Plaintiff has never asserted that illegally marked ballots

are the same thing as “illegal ballots” that are or should be excluded from vote tabulation. The

Plaintiff need not take such a view, because the legal validity of an illegally marked ballot is

irrelevant to deciding whether that ballot is subject to inspection as a public record under CORA.

Furthermore, it is presumably the Defendant’s duty to exclude illegal ballots from tabulation

regardless of whether their public inspection is allowed under CORA.

 

II. The Defendant’s analysis of four TIFF files on the record in the Reply demonstrates

the frivolity of the Defendant’s entire position in this case.

 

The Reply presents an extensive discussion of four individual TIFF files that the

Defendant has referenced for the first time in her Reply. (Def.’s Repl. Mem. Supp. Mot. Dismiss

at 18-21, Ex. B-E.) This discussion is intended by the Defendant to “reveal[] how absurd

Plaintiff’s argument really is.” (Id. at 18-19.) Instead, it showcases the frivolity of the

Defendant’s own position that TIFF files should be treated as ballots under Section 31-10-

616(1), C.R.S.

 

The Defendant has belied nearly all of her substantive arguments by publicly revealing

the contents of four TIFF files in a public filing. Given the Defendant’s insistence that a copy of

a ballot is for all relevant purposes the same thing as a ballot, (Def.’s Repl. Mem. Supp. Mot.

Dismiss at 11), it is significant that the Defendant apparently perceived no obligation – and

undertook no effort – to file Exhibits B, C, D or E under seal or to submit them separately to the

Court for an in camera review. It is particularly difficult to reconcile the Defendant’s casual

handling of these four exhibits with her insistence that the Plaintiff must not be permitted to

inspect any TIFF files, including even those very TIFF files actually pictured in Exhibits B, C, D

and E.

The Colorado Court of Appeals has ruled that, where public records are legally accessible

from private entities, it would be an absurd result for those same records, if in the custody of a

public entity, not to be available for inspection under CORA. See Bodelson v. City of Littleton,

36 P.3d 214, 217 (Colo. App. 2001). The Defendant admits that Exhibits B, C, D and E are but

four of the “468 images that are available for public inspection by viewing the television show,”

which continues as of the date of this filing to be available for download from a non-public

entity’s website on the Internet. (Def.’s Repl. Mem. Supp. Mot. Dismiss at 3.)

 

The Defendant’s case is based on the untenable claim that the Plaintiff’s inspection of

ballot images violates Colorado law because copies of ballots held on a disk must be treated as

ballots, but it is no violation of law for the Defendant to facilitate the video broadcast of 468

images of those same ballots. The Defendant only emphasizes the incoherence between her

arguments and her conduct when she attaches four of those very same images as exhibits to a

pubic legal filing without observing any of the safeguards against public disclosure that would

appear to be required by law under the Defendant’s own legal theory.

 

III. The Defendant’s argument that legislative facts may be used to support her

substantial injury position does not overcome Pinder, Koch and Quiroz.

The Reply also presents an extensive discussion of legal authorities that the Defendant

has referenced for the first time in her Reply. This discussion is intended by the Defendant to

persuade the Court to rely upon legislative facts asserted by motion as a substitute for facts

submitted by affidavit or alleged in any responsive pleading. (Def.’s Repl. Mem. Supp. Mot.

Dismiss at 21-26.)

 

Regardless of whether the Court may consider legislative facts in determining whether

inspection of TIFF files would do substantial harm to the public interest under Section 24-72-

204(6), C.R.S., the Defendant’s assertion that judicial notice of her adduced legislative facts will

“preclude any argument from the Plaintiff that there are material facts in dispute in the case at

bar,” (Id. at 21), is entirely specious. None of the new legal authorities cited by the Defendant in

her Reply suggests that legislative facts ever displace consideration of those material facts

otherwise alleged by the parties in the pleadings, or indeed can do anything more than

supplement the facts alleged by the parties.

 

Given that the Plaintiff has alleged facts that are material to determining whether

substantial injury to the public interest will occur, (V. Compl. ¶¶ 4-5, 20, 22-23, 26-31, 39); given

that this determination for CORA purposes is a question of material fact, see Civil Serv. Comm'n

v. Pinder, 812 P.2d 645 (Colo. 1991); given that the material facts are disputed between the

parties; and given that a judgment on the pleadings is not appropriate where material facts are in

dispute, see Koch v. Whitten, 140 Colo. 109 (1959), 342 P.2d 1011 (Colo. 1959); Quiroz v. Goff, 46

P.3d 486 (Colo. App. 2002), it would be improper for the Court to grant a judgment for the

Defendant on the grounds of substantial injury to the public interest. The Defendant’s assertion

of legislative facts weighing in her favor is irrelevant to the disposition of the Defendant’s

Motion to Dismiss.

CONCLUSION

For the foregoing reasons and those set forth in the Memorandum of Marilyn Marks,

Plaintiff, in Response to Defendant’s Motion to Dismiss, the Plaintiff respectfully requests that

the Defendant’s Motion to Dismiss be denied.

 

Respectfully submitted this 11th day of December, 2009.

 

 By: S/ Robert A. McGuire_______________

 Robert A. McGuire, Reg. No. 37134

1624 Market Street, Suite 202

Denver, Colorado 80202

(303) 734-7175

(303) 734-7166 Fax

ram@lawram.com

 Attorney for Plaintiff Marilyn Marks

 

CERTIFICATE OF SERVICE

I hereby certify that on this 11th day of December, 2009, I served a true and correct copy of

the foregoing SURRELY IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS

by the method indicated below to each of the following:

Attorney Firm And/Or Address: Method

John Worcester City Attorney Lexis Nexis File & Serve

 City of Aspen, Colorado

130 S Galena

Aspen, Colorado 81611

James R. True Special Counsel Lexis Nexis File & Serve

 City of Aspen, Colorado

130 S Galena

Aspen, Colorado 81611

 S/ Robert A. McGuire_______________

 Robert A. McGuire, Reg. No. 37134

1624 Market Street, Suite 202

Denver, Colorado 80202

(303) 734-7175

(303) 734-7166 Fax

ram@lawram.com

 Attorney for Plaintiff Marilyn Marks

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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