STATE OF COLORADO

OFFICE OF ADMINISTRATIVE COURTS

CASE NO.OS20160024
Administrative State Court
1525 Sherman Street
Denver, Colorado 80203
Web page: www.Colorado.gov/OAC
Phone 303-866-2000
_________________________________
PETER COULTER,
Complainant,
v.
COLORADO JUDICIARY et.al.,
Respondents.

Peter Coulter, pro se

151 Summer Street,#654
Morrison, Colorado, 80465
Phone 720 549-5349
TransparentCourts@gmail.com

COMPLAINANTS FIRST SET OF INTERROGATORIES AND

REQUEST FOR PRODUCTION OF DOCUMENTS
Comes the Complainant Peter Coulter, acting pro se, and
propounds his first set of interrogatories and request for
production of documents pursuant to Rules 33 and 34 of the
Colorado Rules of Civil Procedure. The Complainant asks
that all Respondents represented by either the Colorado
Attorney General or Denver County Attorneys Office answer
the interrogatories and document requests by 11:59pm
Wednesday, November 2nd, 2016, appending the requested
documents to those Answers.
INSTRUCTIONS

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The Interrogatories are being forwarded in Word for

ease of responding to each question without attaching a
separate answer sheet. Please attach any documents to the
end of these interrogatories and return only by electronic
reply.
The following instructions apply to these
interrogatories and request for production of documents:
1. Pursuant to Civil Rule 26(e), these interrogatories
are continuing so as to require the filing of subsequent
answers promptly in the event that Respondents, by or
through any of their agents, counsels or other
representatives, learn additional facts relevant to any
answers not set forth in their answers to these
Interrogatories or discover that any information given in
an answer or answers is erroneous.
2. Each interrogatory is to be answered separately and
as completely as possible. The fact that investigation is
continuing or that discovery is not complete does not
excuse failure to answer each interrogatory as fully as
possible. The omission of any name, fact, or other item of
information from an answer shall be deemed a representation
that such name, fact, or other item is not known to
Respondents, his agents, counsel, or other representatives
at the time the answers to these Interrogatories are served
upon Complainant.
3. For each and every answer to these Interrogatories:
a. Identify each and every person who participated in
supplying information and/or drafting your response or any
part thereof;
b. If the answer to any of these Interrogatories was
made by referring to or reviewing any documents, identify
each and every document referred to or reviewed and the
Interrogatory or Interrogatories in connection with which
they were used.
4. As used in these Interrogatories the singular shall
be deemed to include the plural, the plural to include the
singular, and words in the masculine, feminine, or neuter
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shall include each of the other genders as necessary to

make the Interrogatory inclusive rather than exclusive.
5. Where an Interrogatory contains a general question
or questions, followed by a specific question or questions,
the specific question or questions are to be read and
interpreted as requesting additional information, not as
limiting the general question or questions.
6. With respect to each Interrogatory, identify each
and every document prepared by, or in the possession,
custody, or control of you or any of your officers, agents,
or employees that relates to or refers to the subject
matter of the Interrogatory in question.
7. Whenever information is requested in one of the
following Interrogatories or subparts thereof that you
previously furnished in answer to another Interrogatory
herein, such information need not be restated. It will be
sufficient for you to identify the previous answer
containing the information requested.
8. Whenever an Interrogatory calls for information that
is not available to you in the form requested but which is
available in another form or can be obtained at least in
part from other data in your possession, so state and
either (i) supply the information requested in the form in
which it is available or (ii) supply the data from which
the information requested can be obtained.
9. If you claim a privilege with respect to information
pertaining to any document that you are asked to identify
or describe in these Interrogatories, furnish a list signed
by counsel giving the following information with respect to
each such document:
a. The title of the document;
b. The nature of the document, e.g., interoffice
memorandum, correspondence, report, etc.
c. The identity of the sender and the identity of the
recipient(s) of the document;

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d. A statement of the basis upon which the privilege is

claimed and a summary of the subject matter of the document
in sufficient detail to permit the Court to rule on the
propriety of the claim of privilege; and
e. The paragraph number of the Interrogatory to which
the document is responsive or otherwise pertains.
10. Interrogatories calling for numerical or
chronological information shall be deemed, to the extent
that precise figures or dates are not known, to call for
estimates. In each instance that an estimate is given,
identify it as such together with the source of information
upon which you base the estimate.
11. In answering these Interrogatories every source of
information to which you have access should be consulted,
regardless of whether the source is within your immediate
possession or control. All documents or other information
in the possession of experts or consultants should be
consulted.

DEFINITIONS
The following definitions apply to these
Interrogatories and request for production of documents:
EDUCATION Within the meaning of a statute relative to
the powers and duties of guardians, this term comprehends
not merely the instruction received at school or college,
but the whole course of training, moral, intellectual, and
physical. Education maybe particularly directed to either
the mental, moral, or physical powers and faculties, but
In its broadest and best sense it relates to them all.
Mount Herman Boys'School v. Gill, 145 Mass. 139, 13 N. E.
354; Cook v. State, 90 Tenn. 407, 10 S. W. 471,13 L. It. A.
183; Ruohs v. Backer, 6 Heisk. (Tenn.) 400, 19 Am. Rep.
598. [Blacks Law Dictionary, 2nd edition]
PROPAGANDA
A message that is aimed at a specific audience that will
try to change their thinking to that of the person
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releasing such propaganda. It will often contain

disinformation to promote a certain view point in politics.
[Blacks Law Dictionary, 2nd edition]
INTERROGATORIES
INTERROGATORY NO. 1:
Please identify any persons starting with yourself, by
name, address, and position who answered or assisted in
answering these Interrogatories.
RESPONSE:
INTERROGATORY NO. 2:
Have you read the entire Complaint filed by the
Complainant Peter Coulter?
RESPONSE:

INTERROGATORY NO. 3:
Are you aware that a Judge running for Retention is a
Political Candidate for purposes of Colorado Constitutional
Campaign Finance laws?
RESPONSE:
INTERROGATORY NO. 4:
Are you aware that any party who has donations, either cash
or in kind or expenditures more than $200 for a political
candidate or issue campaign must register with the Colorado
Secretary of State and file mandatory financial reports
pursuant to Colorado Constitution Article XXVIII and the
Statutory Fair Campaign Practice Act?
RESPONSE:

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INTERROGATORY NO. 5:
Do you believe that Judicial Retention Recommendations
that are not done in accordance with the mandates of CRS
13-5.5-101 et. seq. are fair?
RESPONSE:

INTERROGATORY NO. 6:
Do you believe that recommending false and/or biased
information is educational or propaganda as defined by
Blacks Law Dictionary above cited? Explain the reasoning
for your response.
RESPONSE:

INTERROGATORY NO. 7:
After reading the Complaint, do you believe the
respective State and District Judicial Performance
Commissions were provided unbiased and valid information to
make their recommendations where non-statistical sampling
methods and arbitrary decisions left out segments of
eligible survey recipients required under the Judicial
Performance Statute?
RESPONSE:

INTERROGATORY NO. 8:
When did you become aware that there were ads placed on
radio and TV media by the Judiciary for the 2016 Judicial
Retention of 107 Judges and Judicial Non-Retention of 3
judges?
RESPONSE:

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INTERROGATORY NO. 9:
Only respond to this interrogatory if you are one of
the 109 Judges up for Retention November 8, 2016. What was
the exact date you filed documents requesting that you
wanted to be placed on the 2016 ballot for Retention of
your respective judgeship?
RESPONSE:

INTERROGATORY NO. 10:

Have you ever registered with the Colorado Secretary of
State as either a Political Candidate or Political
Candidate Campaign Commission concerning the 2016 Campaign
cycle with regard to the Retention or Non-Retention of 109
Colorado Judges? If the answer to any of these questions
is yes, please state the particulars including dates and
names filed with the Secretary of State, Campaign Finance.
RESPONSE:

INTERROGATORY NO. 11:

Do you believe that members of the Judiciary can
arbitrarily and secretly formulate parameters for the
statistically invalid selection of parties to receive
surveys pursuant to CRS 13-5.5 et. seq. without the review
and/or knowledge of the Colorado State Judicial Performance
Commission and/or Colorado Supreme Court? Please explain
your response.
RESPONSE:

INTERROGATORY NO. 10:

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If attorneys have multiple clients in the same matter,

they must disclose the existence of any current or
potential conflicts, and where possible and proper, obtain
waivers of such conflicts in compliance with the applicable
rules of professional responsibility. See ABA Model Rule
1.7(a),(b).
a. Has the Attorney General or Denver County Attorneys
Office disclosed this responsibility to you?
b. Did you sign a waiver with either of the above
attorneys to represent multiple clients in this case? If
so, please submit that waiver.
c. Only Judges running for Retention and were
recommended DO NOT RETAIN [2 Judges] by the Judiciary and
Judges that were up for Retention but decided not to run
for Retention [11 Judges] should respond to this
interrogatory:
Do you believe that an attorney can simultaneously
represent a Judge who has been recommended for Retention
and additionally represent a judge that has been
recommended for non-Retention by Respondent, Judiciary?
RESPONSE:

Respectfully submitted this 28th day of October, 2016.

/s/Peter Coulter
Complainant.

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