Aspen Election Transparency: Marks v. Koch

 

7 Documents and 5 Exhibits:

VERIFIED COMPLAINT AND APPLICATION FOR ORDER DIRECTING CUSTODIAN TO SHOW CAUSE

 

KATHRYN KOCH’S MEMORANDUM IN SUPPORT OF MOTION TO DISMISS

Exhibit A  Calvano v. City of Aspen

Exhibit B Ballot image from GrassRootsTV show

Exhibit C Ballot image from GrassRootsTV show

Exhibit D Ballot image from GrassRootsTV show

Exhibit E Ballot image from GrassRootsTV show

MEMORANDUM OF MARILYN MARKS, PLAINTIFF,IN RESPONSE TO DEFENDANT’S MOTION TO DISMISS

 

MOTION FOR LEAVE TO FILE SURREPLY IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS

 

[PROPOSED] ORDER GRANTING MOTION FOR LEAVE TO FILE SURREPLY IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS

 

KATHRYN KOCH'S MEMORANDUM IN OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO FILE A SURREPLY

 

SURREPLY IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS



 OUTLINE OF DOCUMENTS-  CLICK HERE TO GO DIRECTLY TO THE PORTION SELECTED

 

VERIFIED COMPLAINT AND APPLICATION FOR ORDER DIRECTING CUSTODIAN TO SHOW CAUSE

 

Plaintiff, Marilyn Marks, by and through her undersigned counsel, Robert A. McGuire,

Attorney at Law, LLC, for her Complaint against the Defendant, states as follows:

 

NATURE OF THE COMPLAINT AND APPLICATION

 

PARTIES, JURISDICTION, AND VENUE

 

GENERAL ALLEGATIONS

 

THE PUBLIC RECORDS SOUGHT BY THE PLAINTIFF

 

APPLICABLE PROVISIONS OF CORA

 

THE PLAINTIFF’S CORA REQUEST

 

THE DEFENDANT’S DENIALS OF THE PLAINTIFF’S RIGHT OF INSPECTION UNDER CORA

 

DEFENDANT’S INTENTION TO DESTROY RECORDS

 

CLAIM FOR RELIEF

(Application for Order Directing Custodian to Show Cause

under § 24-72-204(5), C.R.S.)

 

DEMAND FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTIVE RELIEF

 

PRAYER FOR RELIEF

 

VERIFICATION


KATHRYN KOCH’S MEMORANDUM IN SUPPORT OF MOTION TO DISMISS

 

Page 2

 

I. INTRODUCTION

 

II. STANDARD OF REVIEW

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III. MATERIAL FACTUAL ALLEGATIONS

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IV. LEGAL ARGUMENTS

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A. State law requires the city clerk to keep secure and secret all ballots, and ballot images, cast in a municipal election.

1. CORA exempts the public inspection of public records that would be contrary to any

state statute.

 

2. The Colorado Constitution and state statutes prohibit the public disclosure of ballots

and ballot images.

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3. Making ballot images available for public inspection is prohibited by Section 31-10-616(1), C.R.S.

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4. Ballot images should be treated no differently than the original ballots.

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5. The public display of portions of some ballot images on election night cannot

constitute a waiver of voters’ rights to a secret ballot.

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6. CORA should be read in pari materia with §31-10-616(1), C.R.S.

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7. The mandatory destruction of cast ballots is not unique to Colorado.

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B. Making ballots available for public inspection would do substantial injury to the public interest.

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1. Standard of review.

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2. The Public Interest – The right to cast a secret vote.

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3. The Public Interest – Finality in the results of elections.

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4. The Substantial Injury.

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5. The Substantial Injury to the Voters of Aspen.

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6. The substantial injury to voters in the last election.

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7. The substantial injury to voters in all future elections.

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V. CONCLUSION

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CERTIFICATE OF SERVICE

 

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MEMORANDUM OF MARILYN MARKS, PLAINTIFF, IN RESPONSE TO DEFENDANT’S MOTION TO DISMISS

 

STATEMENT OF THE FACTS

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STATEMENT OF THE CASE

 

ARGUMENT

Page 3

 

I. This Court should not dismiss the Verified Complaint under C.R.C.P. 12(b)(5)

because the Verified Complaint is formally sufficient to state a claim upon which

relief can be granted.

 

A. Standard of review for failure to state a claim under C.R.C.P. 12(b)(5).

Page 4

 

B. The Verified Complaint is formally sufficient under C.R.C.P. 12(b)(5).

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C. Affirmative defenses cannot support a dismissal under C.R.C.P. 12(b)(5).

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II. Even if the Court evaluates the Defendant’s Motion to Dismiss as a motion for

judgment on the pleadings under C.R.C.P. 12(c), the Court should still deny the

Defendant’s Motion to Dismiss because none of the Defendant’s affirmative defenses

entitles the Defendant to a judgment on the pleadings.

Page 7

 

A. Standard of review for judgment on the pleadings under C.R.C.P 12(c).

 

B. The Defendant is not entitled to a judgment on the pleadings on the basis of

Article VII, Section 8, of the Colorado Constitution because the public

inspection of TIFF files does not violate secrecy in voting.

Page 8

 

1. The Colorado Constitution protects as secret the anonymity of ballots,

not their content.

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2. Secrecy in voting cannot be violated by the public inspection of an

anonymous TIFF file created from an anonymous, unmarked ballot.

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3. The act of illegally marking a ballot should be interpreted under

Mahaffey as a determination by the voter not to invoke the personal

privilege of secrecy in voting.

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C. The Defendant is not entitled to a judgment on the pleadings on the basis of a

contrary state statute because Section 31-10-616(1), C.R.S., is not properly

construed as contrary to public inspection of the TIFF files.

 

1. Exceptions to the general right of public inspection under CORA are to

be narrowly construed and must be specifically provided by law if set out

in contrary statutes.

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2. Section 31-10-616(1), C.R.S., is nothing more than a records

preservation statute that requires a particular method of storage for

ballots.

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3. The TIFF files cannot properly be construed to be “ballots” under

Section 31-10-616(1), C.R.S.

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4. Even if the Court does regard the TIFF files as ballots, Section 31-10-

616(1), C.R.S., still does not create an exception that is sufficiently

specific under Dreyfus to overcome CORA’s legislative intent for

election records to be open to public inspection.

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D. The Defendant is not entitled to a judgment on the pleadings on the basis of

the defense that inspection of the TIFF files will do “substantial harm to the

public interest” because material facts are in dispute and therefore judgment

on the pleadings is inappropriate.

 

1. Under Pinder, the question of whether disclosure of a public record will

do “substantial harm to the public interest” under Section 24-72-204(6),

C.R.S., is an issue of material fact.

 

2. Under Koch and Quiroz, judgment on the pleadings is not appropriate

where material facts are in dispute.

 

3. Material facts are in dispute on the question of whether disclosure of the

TIFF files would do substantial injury to the public interest.

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CONCLUSION

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CERTIFICATE OF SERVICE

 


 

MOTION FOR LEAVE TO FILE SURREPLY IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS

 

RECITATION OF LEGAL AUTHORITY

CERTIFICATE OF SERVICE

 


 

[PROPOSED] ORDER GRANTING MOTION FOR LEAVE TO FILE SURREPLY IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS

 


KATHRYN KOCH'S MEMORANDUM IN OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO FILE A SURREPLY

 

I. INTRODUCTION
Page 2
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II. ARGUMENTS

 

 A. Defendant did not refer to any facts not included in previous pleadings.

 

  1. Plaintiff did, in fact, acknowledge that much of Plaintiff’s factual allegations in her Complaint are immaterial to the issues in the case at bar.
Page 4

 

  2. Plaintiff did, in fact, acknowledge that certain ballots have identifying information in the form of write-in votes.

 

  3. Plaintiff has, in fact, claimed that the election could be challenged for being unconstitutional.
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  4. Plaintiff has, in fact, argued that ballots that are illegally marked should not be counted.
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 B. Defendant’s analysis of the four TIFF files does not refer to any facts not included in previous pleadings.
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 C. Defendant’s argument that legislative facts may be used to support her substantial injury position requires no surreply from the Plaintiff.
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III. CONCLUSION

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CERTIFICATE OF SERVICE

 

JPW-12/16/2009-90624-G:\john\word\plead\Marks - CORA\memo opp to surreply.doc


SURREPLY IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS

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

statements and legal arguments.

 

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.

 

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

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

 

CONCLUSION