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Court Address:
1777 Sixth Street P.O. Box 4249, Boulder, CO, 80306-4249
Plaintiff(s) MICHAEL DAVIS et al.
v.
PATRICK D BUTLER
District Court Judge
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______________________________________________
Attorneys for Plaintiffs:
Richard A. Westfall, Reg. No. 15295
Andrea Dalton, Reg. No 35076
Hale Westfall, LLP
600 Stout Street, Suite 500
Denver, Colorado 80202
Telephone:
(720) 904-6000
E-mail:
rwestfall@halewestfall.com
adalton@halewestfall.com
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Plaintiffs Michael Davis and the Boulder County Republican Party, respectfully request
that this Court reconsider its order dated November 3, 2014, and issue the relief Plaintiffs have
requested in their Verified Complaint Pursuant to C.R.S. 1-1-113 and for Injunction and
Temporary Restraining Order. In support, Plaintiffs state as follows:
1.
This Court denied Plaintiffs request on the grounds that no notice to the official
has been shown or provided. No opportunity to be heard has occurred. Order, 7. In addition,
this Court noted that no certification was provided concerning the efforts made, if any, to give
notice. Id., 8.
2.
Undersigned counsel hereby certifies that he has had personal contact with
Deputy County Attorney David Hughes concerning the relief sought by Plaintiffs. Earlier today,
counsel spoke with Mr. Hughes by phone twice, and provided a copy of the Verified Complaint
and supporting motion by e-mail at approximately 12:50 p.m.
3.
Having provided the requisite notice to counsel for Defendant Hall, Plaintiffs
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respectfully request this Court to reconsider its decision and issue the relief requested by
Plaintiffs for the reasons set forth in Plaintiffs Verified Complaint and supporting motion.
Dated this 3rd day of November, 2014.
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s/Richard A. Westfall
Richard A. Westfall, No. 15295
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CERTIFICATE OF SERVICE
I hereby certify that on this 3rd day of November, 2014, a true and correct pleading was
served via e-mail on the following:
David Hughes
Boulder County Attorneys Office
P.O. Box 471
Boulder, CO 80306
dhughes@bouldercounty.org
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Matthew D. Grove
Assistant Attorney General
1300 Broadway, 10th Floor
Denver, CO 80203
matt.grove@state.co.us
Counsel for the Secretary of State
Martha Tierney
Heizer Paul LLP
2401 15th St., Suite 300
Denver, CO 80202
mtierney@hpfirm.com
Counsel for the Colorado Democratic Party
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s/Bethany Lillis
Bethany Lillis
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