STATE OF COLORADO OFFICE OF ADMINISTRATIVE COURTS: 1525 Sherman Street, 4" Floor Denver, CO 80203 Peter Coulter, Complainant ACOURT USE ONLY & v. Colorado Judiciary, et al., Case No. OS-2016-0024 Respondents. a ‘Attorney for the following Denver County Court Judges ‘named in the Complaint: Hon, John M. Marcucei; Hon. Doris E. Burd; Hon. Beth A. Faragher; Hon. Gary M. Jackson; Hon. Nicole M. Rodarte; Hon. Andre L. Rudolph; Hon. Theresa A. Spahn DAVID W. BROADWELL, Assistant City Attomey for the City and County of Denver Atty. Reg. No, 12177 1437 Bannock St. Room #353 Denver, CO 80202 Telephone: 720-865-8754 Facsimile: 720-865-8796 Email: david broadwell@denvergov.org, RENEWED MOTION TO DISMISS DENVER COUNTY COURT JUDGES Having reviewed the First Amended Complaint, the Respondents, the Denver county court, judges, hereby renew their original motion dated October 27, 2016 seeking the dismissal of the Denver judges from this case. For the reasons set forth in Denver's original motion, the Denver judges should be dismissed pursuant to Rule 12(b)(1), C.R.C.P. due to this court’s lack of subject ‘matter jurisdiction over any Denver charter officer in regard to campaign finance complaints. Denver acknowledges that, if this Court grants the State Judicial Defendants’ motion to dismiss the entire First Amended Complaint for failure to state a claim upon which relief may begranted, the Court may deem it unnecessary to rule on Denver's own motion to dismiss. However, Denver would respectfully urge the Court to grant both motions in order to impress upon the Complainant that, regardless of how or whether he chooses to retool and refile his complaint and name state court judges in any future campaign finance complaint, he should not attempt to include Denver county court judges in any such complaint due to this court’s lack of jurisdiction over such judges under In re the complaint filed by the City of Colorado Springs, 277 P.3d 937 (Colo. App. 2012). RESPECTFULLY SUBMITTED this 10" Day of November, 2016. David W. Broadwell, 1217 Attomey for the Respondents, Denver County Court JudgesCERTIFICATE OF SERVICE Thereby certify that today, November 10,2016, I electronically served the foregoing Entry of Appearance on the following parties: Peter Coulter 151 Summer Street, #654 Morrison, CO 80465 transparenteou Leom Pro se Complainant ‘Matthew D. Grove, Assistant Solicitor General Christopher M. Jackson, Assistant Attomey General Ralph L. Carr Colorado Judicial Center 1300 Broadway, 6" Floor Denver, CO 80203 mall grove@coag.u christopher jackson@coay.gov Attorneys for Respondents Colorado Judiciary, et al Martha M. Tiemey, Atty Reg. #27521 TIERNEY LAWRENCE LLC 225 E 16th Avenue, Suite 350 Denver, CO 80203 Telephone: (720) 242-7577 E-mail: mtierneyticrneylawrenee.com (s/ David W. Broadwell City and County of Denver