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Matt Arnold

Campaign Integrity Watchdog


P.O. Box 372464
Denver, Colorado 80237
campaignintegritywatchdog@gmail.com
Christopher M. Jackson
Assistant Attorney General
1300 Broadway, 6th Floor
Denver, CO 80203
(720) 508-6157
christopher.jackson@coag.gov
Re: OAC Case No. OS2016-0026, Campaign Integrity Watchdog (CIW) v. Colorado Office
of Judicial Performance Evaluation (COJPE)
Mr. Jackson,
Pursuant to Office of Administrative Courts Rule 9(A) and Colorado Rules of Civil Procedure
(C.R.C.P.) 26 and 34, below please find the following interrogatories and requests for the
production of documents propounded by Complainant Campaign Integrity Watchdog (CIW) to
Respondents Colorado Office of Judicial Performance Evaluation (COJPE):
Interrogatories:
1. Identify each and every individual who contributed to providing substantive responses to
these interrogatories.
2. Identify the individual(s) within the COJPE with authority to appropriate and/or disburse
funds for communications directed to the general public, whether styled as education,
outreach, public relations, public service announcements or any like description.
3. Identify the amount of public funds appropriated and/or disbursed to fund TV and/or radio
advertisements directing the audience to the www.gettoknowyourjudge.com website for
information on candidates for (judicial) public office in the November 2016 election.
4. Identify the source of public funds appropriated and/or disbursed to fund TV and/or radio
advertisements directing the audience to the www.gettoknowyourjudge.com website for
information on candidates for (judicial) public office in the November 2016 election.
5. Identify when public funds were appropriated and/or disbursed to fund TV and/or radio
advertisements directing the audience to the www.gettoknowyourjudge.com website for
information on candidates for (judicial) public office in the November 2016 election.
6. Identify the dates of broadcast for the TV and/or radio advertisements directing the audience
to the www.gettoknowyourjudge.com website for information on candidates for (judicial)
public office in the November 2016 election, including start/end dates for airing all ads.

7. Identify who purchased the domain/URL for the www.gettoknowyourjudge.com website.


8. Identify the amount and source of funds used to purchase the www.gettoknowyourjudge.com
website domain, hosting, design, production, operation, and maintenance.
9. Identify when the www.gettoknowyourjudge.com website domain was purchased, when the
site was designed/produced, and when the website became operational.
10. List each and every individual COJPE intends to call as a witness at hearing.
11. Identify in detail the substance of the anticipated testimony to be offered by each witness that
COJPE will call at hearing.
12. Identify any COJPE appropriations/disbursements for advertisements, educational efforts,
outreach, public service announcements or similar spending in the 2014 election cycle,
including amount/source of funds and medium of communications used.
13. Identify any COJPE appropriations/disbursements for advertisements, educational efforts,
outreach, public service announcements or similar spending in the 2012 election cycle,
including amount/source of funds and medium of communications used.
14. Identify any COJPE appropriations/disbursements for advertisements, educational efforts,
outreach, public service announcements or similar spending in the 2010 election cycle,
including amount/source of funds and medium of communications used.
15. Identify any/all COJPE appropriations/disbursements for advertisements, educational
efforts, outreach, public service announcements or similar spending in previous election
cycles, including amount/source of funds and medium of communications used.

Request for Production:


1. Produce all communications, including but not limited to hardcopy letters, E-mails and text
messages, between any member of the Colorado Office of Judicial Performance Evaluation
(COJPE) and any officer, agent, or employee of the Colorado Broadcasters Association
(CBA) between 1 August 2016 and 28 November 2016.
2. Produce all records of appropriations and/or disbursement of funds for production and/or
dissemination of multiple variants of TV/radio advertisements directing the audience to the
www.gettoknowyourjudge.com website for information on candidates for (judicial) public
office in the November 2016 election.
3. Produce all invoices of services for production and/or dissemination of multiple variants of
TV/radio advertisements directing the audience to the www.gettoknowyourjudge.com
website for information on candidates for (judicial) public office in the November 2016
election.
4. Produce all invoices for purchase of the domain, design, production, operation, and/or
maintenance of the www.gettoknowyourjudge.com website.

5. Produce video/audio recordings and transcripts of the following advertisements:


a. 15-second get to know your judge radio advertisement
b. 30-second get to know your judge radio advertisement
c. 60-second get to know your judge radio advertisement
d. 30-second get to know your judge TV/video advertisement
e. Any additional get to know your judge advertisements in any medium
6. Produce screenshots of the www.gettoknowyourjudge.com website.

For purposes of the foregoing requests, the term "document" means all materials within the
scope of Colorado Rule of Civil Procedure 34, including all correspondence, electronic mail, text
messages, memoranda, records, reports, notes, notebooks, diaries, calendars, plans, drawings,
sketches, diagrams, photographs, photocopies, charts, graphs, minutes of meetings, conferences
and telephone or other conversations, drafts, proposals, books, papers, computations, tabulations,
schedules, lists, proposals, specifications, invoices, purchase orders, vouchers, checks, books of
original entry and other books of records, recordings, publications, or any other written, printed,
typewritten or other graphic or photographic matter or tangible thing on which any words or
phrases are affixed, including microfilm, microfiche, or other reproductions of film impressions,
all mechanical and electronic sound or video recordings or transcripts of the above, all magnetic
recordings or matter existing in any other machine-readable form however produced or
reproduced. The term "document" includes all forms of electronically stored information,
whether fixed in a tangible form or stored in any form of medium from which it can be retrieved.
Please deliver all documents responsive to the foregoing requests to the undersigned pro se
representative for the Complainant no later than 1 December 2016. All documents that are stored
electronically should be produced either as native files or in a searchable PDF format.
Regards,
___/signed/ Matt Arnold________________
MATTHEW ARNOLD, pro se for
Campaign Integrity Watchdog
P.O. Box 372464
Denver, Colorado 80237

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