Professional Documents
Culture Documents
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