COLORADO SECRETARY OF STATE

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

Peter Coulter, pro se

151 Summer Street,#654
Morrison, Colorado, 80465
Phone 720 539-549-5349
TransparentCourts@gmail.com
COMPLAINANTS FORTHWITH MOTION TO COMPEL RESPONDENTS
JUDICIARY AND CBA TO DISCLOSE RADIO STATIONS IDENTITIES
COMES NOW the Complainant, Mr. Peter Coulter to pray the Court
forthwith

compel

Respondents,

Colorado

Judiciary

and

Colorado

Broadcasters Association [CBA] to disclose the names and contact

information of Respondents, unknown radio stations. As good and
sufficient cause the Complainant states as follows:
1.

Mr. Coulter has tried to correspond with both Respondents

Judiciary and CBA in an effort to resolve this issue without

involving

the

Complaint]
Page 1 of 3 Coulter v. Judiciary

Court

with

no

success.

[See

Exhibit

16

of

2.

The

Complainant

files

this

Forthwith

Motion

contemporaneously with the Complaint in an effort to get the

names of additional Respondent radio stations that are unknown
to Mr. Coulter but believes they are well known to above
Respondents

who

he

believes

are

holding

the

information

hostage in an effort to delay/stop/end this Campaign Finance

Complaint to hide their fraudulent actions in the Retention of
Colorado Judges.
3.

As described in the Complaint, there are radio stations

that have aired political candidate ads starting October 1,

2016 and continuing until November 8, 2016; election day.
4.

By law the hearing for the Complaint must occur within 15

days of the submittal of the Complaint; October 18, 2016.

5.

The Complainant needs the names and contact information

so he can Amend the complaint and notify the unknown radio

stations of the Complaint and hearing date.
6.

The only possible way for the Complainant to get this

information is from the above Respondents.

WHEREFORE, the Complainant Peter Coulter requests the Court
ORDER

that

Respondents

Colorado

Judiciary

and

Colorado

Broadcasters Association Forthwith provide Mr. Coulter with

the names of radio stations that to date have aired any of
the

ads

of

the

Judiciary

as

further

described

in

the

Complaint,
AND for such further relief that the Court deems just and
proper.
Respectfully submitted this 19th day of October, 2016.

/s/Peter Coulter
Complainant
Page 2 of 3 Coulter v. Judiciary

CERTIFICATE OF SERVICE
I certify that on 10/19/2016 a true and correct copy of the above Motion to Compel was served on each of
the following:
Name of Person to Whom
you are Sending this
Document

Party

Address

Manner of
Service*

Judiciary.

Christopher.Ryan@judicial.state.co.us Ct. Clerk

Terri.Morrison@judicial.state.co.us
Counsel

christopher.ryan@judicial.state.co.us
Terri.Morrison@judicial.state.co.us

E-MAIL

Governor Hickenlooper

Respondent
C/O
Justice
Nancy Rice
Respondents
C/O
Justice
Nancy Rice
Respondent

Governor.Hickenlooper@state.co.us

E-MAIL

Judge Nancy Rice

Respondent

Christopher.Ryan@judicial.state.co.us
Terri.Morrison@judicial.state.co.us

E-MAIL

Supreme Court Judges

Respondents

Christopher.Ryan@judicial.state.co.us
Terri.Morrison@judicial.state.co.us

E-MAIL

Gerrald Marroney

Respondent

Gerald.Marroney@judicial.state.co.us

E-MAIL

Kent Wagner

Respondent

Kent.Wagner@judicial.state.co.us

E-MAIL

Judicial
Performance
Commission Members

Respondent

Kent.Wagner@judicial.state.co.us

E-MAIL

109 Judicial Retention

Judges

E-MAIL

campaignfinance@sos.state.co.us

Campaign Finance,
CO. Secretary of State

E-MAIL

Mr. Justin Sasso

Colorado Broadcasters
Association

Respondents

104.3THE FAN

Respondent

Ms. Cynthia Coffman

Colorado
Attorney
General

Justin@ColoradoBroadcasters.org
CBA@ColoradoBroadcasters.org

E-MAIL

Armen@104.3thefan.com

E-MAIL

attorney.general@state.co.us

*Insert one of the following: Hand Delivery, First-Class Mail, Certified Mail, E-Served or Faxed.
/s/ Peter Coulter

Page 3 of 3 Coulter v. Judiciary

E-MAIL