Human Rights Defense Center v. Board of County Commissioners for Jefferson County, CO, Complaint, Censorship, 2025
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Case No. 1:25-cv-00164 Document 1 filed 01/16/25 USDC Colorado pg 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No._______ HUMAN RIGHTS DEFENSE CENTER, Plaintiff, v. BOARD OF COUNTY COMMISSIONERS FOR JEFFERSON COUNTY, COLORADO; REGGIE MARINELLI, Sheriff, in her official and individual capacities; GARY GITTINS, Detention Division Chief, in his individual capacity; and DOES 1-10, in their individual capacities, Defendants. COMPLAINT AND JURY DEMAND INTRODUCTION Plaintiff, Human Rights Defense Center (“HRDC” or “Plaintiff”), brings this action to enjoin Defendants from censoring publications that Plaintiff mails to prisoners who are held in custody at the Jefferson County Detention Facility (“Detention Facility”), in violation of the First and Fourteenth Amendments of the United States Constitution. For decades, the United States Supreme Court has recognized that the freedom to read and correspond with the outside world while incarcerated carries important benefits to both prisoners and society as a whole. To this end, plaintiff, HRDC provides prisoners across the United States with publications about their legal and civil rights, as well as options for accessing education while incarcerated. Some of these publications are periodicals and some are books. At times HRDC will Case No. 1:25-cv-00164 Document 1 filed 01/16/25 USDC Colorado pg 2 of 17 send information that is requested by prisoners, and at other times HRDC will send information unsolicited to assist prisoners and in furtherance of its mission to educate prisoners. Defendants have adopted and implemented mail policies and practices prohibiting delivery of written speech from HRDC. Defendants’ actions violate HRDC’s rights under the First and the Fourteenth Amendments of the United States Constitution. HRDC thus brings this action, pursuant to 42 U.S.C. § 1983, seeking injunctive and declaratory relief and damages to be proven at trial. JURISDICTION AND VENUE 1. This action is brought pursuant to 28 U.S.C. § 1331, as it arises under the Constitution and laws of the United States, and pursuant to 28 U.S.C. § 1343, as it seeks redress for civil rights violations under 42 U.S.C. § 1983. 2. Venue is proper under 28 U.S.C. § 1391(b). At least one Defendant resides within this judicial district, and the events giving rise to the claims asserted herein occurred within this judicial district. 3. HRDC’s claims for relief are predicated upon 42 U.S.C. § 1983, which authorizes actions to redress the deprivation, under color of state law, of rights, privileges, and immunities secured to Plaintiff by the First and Fourteenth Amendments of the U.S. Constitution and laws of the United States. 4. This Court has jurisdiction over claims seeking declaratory and injunctive relief pursuant to 28 U.S.C. §§ 2201 and 2202, as well as claims seeking nominal and compensatory damages against all Defendants. 2 Case No. 1:25-cv-00164 5. Document 1 filed 01/16/25 USDC Colorado pg 3 of 17 HRDC’s request for attorneys’ fees and costs is predicated upon 42 U.S.C. § 1988, which authorizes the award of attorneys’ fees and costs to prevailing plaintiffs in actions brought pursuant to 42 U.S.C. § 1983. PARTIES 6. HRDC is a not-for-profit charitable organization recognized under § 501(c)(3) of the Internal Revenue Code, incorporated in the state of Washington and with principal offices in Boynton Beach, Florida. 7. Defendant Board of County Commissioners for Jefferson County (“Jefferson County”) is the governing body for Jefferson County, Colorado, a formally constituted political subdivision of the state of Colorado. Jefferson County has delegated its authority for the operation of the Detention Facility to Sheriff Reggie Marinelli. 8. Defendant Reggie Marinelli (“Marinelli”) is the elected Sheriff of Jefferson County, Colorado, to whom Jefferson County has delegated the operation of the Detention Facility. Sheriff Marinelli is responsible for overseeing the management and operations of the Detention Facility, and for the hiring, screening, training, retention, supervision, discipline, counseling, and control of the personnel of the Detention Facility who interpret and apply the mail policy to prisoners. As Sheriff, Marinelli is a final policymaker for the Detention Facility with respect all of its operations, including for policies governing incoming mail for prisoners. She is sued in both her official 1 and her individual capacities. 9. Defendant Gary Gittins (“Gittins”) is the Detention Division Chief of the Jefferson County Sheriff’s Office. Gittins is employed by and is an agent of Defendants Jefferson County and Marinelli. As Chief of the Detention Division, Gittins is responsible for overseeing 1 In lieu of naming the Jefferson County Sherriff’s Office as a Defendant. 3 Case No. 1:25-cv-00164 Document 1 filed 01/16/25 USDC Colorado pg 4 of 17 the management and operations of the Detention Facility, and for the hiring, screening, training, retention, supervision, discipline, counseling, and control of the personnel of the Detention Facility who interpret and apply the mail policy for prisoners. He is sued in his individual capacity. 10. The true names and identities of Defendants DOES 1 through 10 are presently unknown to HRDC. Each of DOES 1 through 10 are or were employed by and are or were agents of the Detention Facility when some or all of the challenged mail policies and practices at the Detention Facility were adopted and/or implemented. Each of DOES 1 through 10 are or were personally involved in the adoption and/or implementation of the Detention Facility’s mail policies for prisoners, and/or are or were responsible for the hiring, screening, training, retention, supervision, discipline, counseling, and/or control of the Detention Facility staff who interpret and implement these mail policies. DOES 1 through 10 are sued in their individual and official capacities. HRDC will seek to amend this Complaint when the true names and identities of DOES 1 through 10 have been ascertained. 11. At all times material to this Complaint, the actions of all Defendants as alleged herein were taken under the authority and color of state law. FACTUAL ALLEGATIONS I. HRDC’s Publications 12. For more than 34 years, the focus of HRDC’s mission has been public education, advocacy and outreach on behalf of, and for the purpose of assisting, prisoners who seek legal redress for infringements of their constitutionally guaranteed and other basic human rights. HRDC’s mission, if realized, has a salutary effect on public safety. 13. To accomplish its mission, HRDC publishes and distributes books, magazines, and other information containing news and analysis about prisons, jails and other detention facilities, 4 Case No. 1:25-cv-00164 Document 1 filed 01/16/25 USDC Colorado pg 5 of 17 prisoners’ rights, court rulings, management of prison facilities, prison conditions and other matters pertaining to the rights and/or interests of incarcerated individuals. 14. HRDC publishes and distributes an award-winning monthly magazine titled Prison Legal News: Dedicated to Protecting Human Rights (“Prison Legal News”), which contains news and analysis about correctional facilities, the rights of prisoners, court opinions, prison and jail conditions, excessive force, and religious freedom. In 2013, Prison Legal News received the First Amendment Award from the Society of Professional Journalists. Prison Legal News is published on newsprint bound by two small staples, and is 72 pages long. 15. HRDC also publishes and distributes a second monthly magazine titled Criminal Legal News, which contains news and analysis about individual rights, court rulings, and other criminal legal-related issues. Criminal Legal News is also published on newsprint bound by two small staples, and is 56 pages long. 16. HRDC also publishes and/or distributes several different soft-cover books on criminal justice, health, and legal issues that are of interest to prisoners and others. HRDC publishes and distributes the Prisoners’ Guerilla Handbook: A Guide to Correspondence Programs in the United States and Canada (“Prisoners’ Handbook”), which provides information on enrolling at accredited higher educational, vocational and training schools. HRDC does not publish, but is the sole national distributor of Protecting Your Health and Safety (“PYHS”), which describes the rights, protections and legal remedies available to persons concerning their health and safety while they are incarcerated. 17. In addition to its publications, HRDC also communicates with prisoners through the United States Postal Service by mailing them: (a) informational brochure packets, which contain a brochure and subscription order form, a book list, and a published books brochure (each 5 Case No. 1:25-cv-00164 Document 1 filed 01/16/25 USDC Colorado pg 6 of 17 of which is a single page); (b) copies of judicial opinions of import to prisoners, which are marked “Court Ruling;” and (c) letters that provide pertinent information about HRDC’s publications and related topics and subscription renewal letters. HRDC encloses a self-addressed, stamped envelope with its informational brochure packets and subscription renewal letters, but does not enclose extra envelopes or stamps with the informational brochure packets, judicial opinions, or other letters that it mails to prisoners. 18. HRDC has thousands of subscribers to its monthly magazines in the United States and abroad, including prisoners, attorneys, judges, journalists, libraries, and members of the public. Since its creation in 1990, HRDC has sent its publications to prisoners and law librarians in more than 3,000 correctional facilities across the United States, including death row units and institutions within the Federal Bureau of Prisons, such as the federal Administrative Maximum Facility (“ADX” or “Supermax”) in Florence, Colorado—the most secure prison in the United States. Prison Legal News is distributed to prisons and jails within the correctional systems of all 50 states, including to dozens of prisoners housed in facilities in the State of Colorado. 19. HRDC has been attempting to send these important publications to persons incarcerated at the Detention Facility. Yet Defendants maintain mail policies or practices that unconstitutionally prevent HRDC from sending these materials to individuals incarcerated at the Detention Facility. II. Defendants’ Mail Policies and Practices 20. The Detention Facility’s mail policy (the “Mail Policy”) is available on the public website of the Jefferson County Sheriff’s Office at https://www.jeffco.us/661/Inmate-Mail (last visited January 16, 2025). In pertinent part, the Mail Policy provides: Effective February 15, 2024, all personal mail must be addressed in the following manner: 6 Case No. 1:25-cv-00164 Document 1 filed 01/16/25 USDC Colorado pg 7 of 17 Inmate Name and ID # c/o Securus Digital Mail Center - Jefferson County Jail PO Box 25938 Tampa, FL 33622 • Full name and address of sender must be written in return address • Failure to properly address the envelope will result in the mail being returned to sender • Once the mail is received at the Securus Digital Mail Center, it will be digitally scanned and available to the inmate, to be viewed on module kiosks and tablets. This includes all personal mail from family and friends such as letters, pictures, and drawings. • Any person sending any personal mail that wishes to have it returned to them must include a self-addressed, stamped envelope included with the original mail • Inmate to inmate mail is not permitted • All correspondence will be scanned and inspected for contraband, except mail that is clearly marked “Legal Mail” … We do not allow recreational books to be sent to inmates in our facility. Only preapproved legal or religious books/publications will be allowed. 21. In addition, the Mail Policy contains the following list of “restricted materials” including: • Plans for the introduction of contraband or other criminal activity, including escape or unauthorized entry. • Threats of blackmail and/or extortion. • Instruction for the manufacture of weapons, drugs, drug paraphernalia, alcoholic beverages, or explosives or incendiary devices. • Codes not understood by the scanner, to include gang graffiti or tagging. • Plans for activities in violation of facility rules. • Information, which if communicated, would create danger, interpersonal discord, violence and/or harm to any person. • Mail that contains potentially infectious and/or offensive materials (e.g., bodily fluids). • Sexually explicit photographs, articles, or materials depicting sexual activity or displaying male/female genitalia or breasts. 7 Case No. 1:25-cv-00164 Document 1 filed 01/16/25 USDC Colorado pg 8 of 17 • Any item which promotes racial conflict or discrimination, including illegal gang materials. • Material that would, if communicated, disrupt the operation and/or safety and security of the facility. • Items not authorized for retention (e.g. stickers, postage stamps, envelopes, blank paper, laminated items, plastic or cardboard items, newspaper/magazine clippings, recorded musical cards, cards larger than 8”x11”, drawings or writings made with crayons, Polaroid pictures, stationary items, business cards, lottery tickets, lipstick, glitter, perfumes, ribbons, beads, string, oils, chemicals, liquids, foreign substances, batteries, electronic devices, glue, etc.). • Food items received in the mail will be returned to the sender. • Inmate to inmate mail without pre-approval. • Funds sent, other than the allowable US Postal or international postal money orders, checks from other law enforcement agencies, cashier's checks, or certified funds will be returned to the sender. • Books are prohibited, unless pre-approved by a detention watch commander, or designee. • Parcels/packages are prohibited, unless pre-approved by a detention watch commander, or designee. • Three-way or third-party mail. • Misrepresentation of privileged/legal mail. • Items, whether original or photocopies: credit card(s) and/or account numbers, bank account numbers, checks, deposit slips or any financial statement o personal identification numbers or security codes for any financial transaction or device o o social security card, number or statement driver’s license, passport, passport card, consulate card, tribal identification card o III. o birth certificates, death certificates, or mortuary documents o real estate or property tax documents Defendants’ Censorship of HRDC’s Mail 22. Between June 2023 and December 2024, HRDC sent books, magazines, informational brochures, and correspondence to individuals confined at the Detention Facility. During that time period, ninety-three (93) of those items were returned to HRDC by the Detention 8 Case No. 1:25-cv-00164 Document 1 filed 01/16/25 USDC Colorado pg 9 of 17 Facility. The items returned were addressed to individuals confirmed to still be in custody of the Detention Facility on the day HRDC received the returned mail. 23. The ninety-three (93) returned items consisted of: twenty-eight (28) issues of Prison Legal News; twenty-eight (28) issues of Criminal Legal News; nineteen (19) copies of PYHS; nine (9) copies of Prisoners’ Handbook; five (5) informational brochures; three (3) follow-up letters; and one (1) renewal letter. 24. Many of the rejected items were returned to HRDC marked in various ways, including “VIOLATES DOC MAIL RULE,” “RETURN TO SENDER,” “REJECTED,” AND “RTS.” 25. Because of Defendants’ actions as described above, HRDC has suffered damages, and will continue to suffer damages, including, but not limited to: the suppression of HRDC’s speech; the impediment of HRDC’s ability to disseminate its message; frustration of HRDC’s non-profit organizational mission; the loss of potential subscribers and customers; and, the inability to recruit new subscribers and supporters. 26. Defendants, and other agents of the Detention Facility, are responsible for or personally participated in, creating and implementing these unconstitutional polices, practices, and customs, or for ratifying and adopting them. Further, Defendants are responsible for training and supervising the employees of the Detention Facility, whose conduct has injured and continues to injure HRDC. 27. Defendants’ actions and inactions were and are impermissibly motivated, and were and are all committed under color of state law with deliberate indifference to HRDC’s rights. 9 Case No. 1:25-cv-00164 28. Document 1 filed 01/16/25 USDC Colorado pg 10 of 17 Plaintiff will continue to send its books and magazines to subscribers, customers, and other individuals imprisoned at the Detention Facility. 29. Defendants’ unconstitutional policy, practices, and customs continue to violate HRDC’s rights, and they were and are the moving force behind the injuries HRDC suffered as a direct result of the constitutional violations. As a result, HRDC has no adequate remedy at law. 30. Without relief from this Court HRDC will suffer irreparable injury, since its fundamental free speech and due process rights are being denied. The balance of hardship favors Plaintiff and the public interest will be served by granting injunctive and declaratory relief. 31. The accommodation of the free speech and due process rights of HRDC with respect to written speech protected by the Constitution will not have any significant impact on the Detention Facility, its staff, prisoners, or the public. IV. Defendants’ Failure to Provide Due Process Notice and an Opportunity to Appeal 23. To date, Defendants have failed to provide HRDC with sufficient notice of the reason for the rejection of the magazines, books, and correspondence mailed by HRDC to prisoners at the Detention Facility. 24. Further, Defendants have failed to provide HRDC with an opportunity to appeal these censorship decisions before the items were rejected and returned to HRDC at HRDC’s expense. 10 Case No. 1:25-cv-00164 V. Document 1 filed 01/16/25 USDC Colorado pg 11 of 17 Defendants’ Unconstitutional Mail Policies and Practices Are Causing HRDC Ongoing and Irreparable Harm. 25. Due to Defendants’ actions described above, HRDC has suffered damages, and will continue to suffer damages, including but not limited to: deprivation of its constitutional rights; frustration of its abilities to disseminate its political message, to recruit new subscribers and supporters, and to advance its mission as a not-for-profit organization; significant diversion of its resources, including staff time; loss of potential subscribers and customers; damage to its reputation; and significant printing, handling, and mailing costs. 26. Defendants’ actions and omissions were and are all committed under color of law and with reckless indifference to HRDC’s rights. 27. Defendants and their agents are responsible for—or personally participated in— creating and implementing these unconstitutional policies, practices, and customs, and/or ratifying or adopting them. Further, Defendants Marinelli and Gittins are responsible for training and supervising employees whose conduct has injured and continues to injure HRDC. 28. Defendants’ unconstitutional policies, practices, and customs are ongoing, and continue to violate HRDC’s constitutional rights—causing irreparable harm. Defendants’ unconstitutional policies, practices, and customs will continue unless enjoined. As such, HRDC has no adequate remedy at law. 29. Defendants Marinelli’s and Gittins’s actions – including, but not limited to, their implementation and arbitrary enforcement of an official mail policy – are in violation of clearly established law in this jurisdiction that makes it unlawful for governmental officials to deny persons the right to communicate, via the U.S. Mail, with incarcerated prisoners, absent a legitimate penological justification and without providing notice and an opportunity to the mail sender to challenge any such denial. 11 Case No. 1:25-cv-00164 30. Document 1 filed 01/16/25 USDC Colorado pg 12 of 17 In addition to damages, HRDC is entitled to injunctive relief prohibiting Defendants from unconstitutionally censoring and refusing to deliver HRDC’s mailings and depriving HRDC of due process of law. CAUSES OF ACTION FIRST CLAIM FOR RELIEF Violation of the First Amendment Right to Free Speech and Communication Under 42 U.S.C. § 1983 (Brought Against All Defendants) 31. HRDC repeats and re-alleges each and every allegation set forth above, and incorporates them herein by reference. 32. The acts described above constitute violations of HRDC’s rights under the First Amendment of the U.S. Constitution, as incorporated and applicable to the Defendants under the Fourteenth Amendment. 33. HRDC has a constitutionally protected liberty interest in communicating with incarcerated individuals by sending its materials, including the magazines Prison Legal News and Criminal Legal News, to them via U.S. Mail. Defendants’ unconstitutional censorship violates HRDC’s clearly established right to communicate with these individuals. 34. None of the content in any of the Plaintiff’s publications that Defendants have rejected violates the Detention Facility’s posted mail policy. Nor is there any other non-stated legitimate penological interest justifying Defendants’ unconstitutional censorship. 35. Moreover, Defendants’ apparent requirement that prisoners seek prior approval of published materials before they can be delivered to their intended recipients, supra ¶ 19, serves as a prior restraint on speech, abridging HRDC’s First Amendment rights. 36. Defendants’ conduct is objectively unreasonable and was undertaken recklessly, intentionally, willfully, with malice, and with deliberate indifference to the rights of others. 12 Case No. 1:25-cv-00164 37. Document 1 filed 01/16/25 USDC Colorado pg 13 of 17 HRDC’s injuries and the violations of its constitutional rights were directly and proximately caused by Defendants’ policies and practices; and those policies and practices were the moving force behind the violations. 38. The acts described above have caused HRDC to suffer damages, and if not enjoined, will continue to cause HRDC to suffer damages. 39. HRDC seeks declaratory and injunctive relief against all Defendants, and nominal and compensatory damages against the individual Defendants. HRDC seeks punitive damages against the individual Defendants in their individual capacities. SECOND CLAIM FOR RELIEF Violation of the Fourteenth Amendment Right to Notice and Due Process Under 42 U.S.C. § 1983 (Brought Against All Defendants) 40. HRDC repeats and re-alleges each and every allegation set forth above, and incorporates them herein by reference. 41. The acts described above constitute violations of HRDC’s rights, the rights of other correspondents who have attempted to or intend to correspond with persons incarcerated in the Detention Facility, and the rights of persons incarcerated in the Detention Facility, under the Fourteenth Amendment of the U.S. Constitution. 42. HRDC has a clearly established right under the Due Process Clause of the Fourteenth Amendment to receive notice and an opportunity to object and/or appeal Defendants’ decisions to prevent Plaintiff’s mail from reaching prisoners held in the Detention Facility. 43. Defendants’ policy and practice of censoring HRDC’s publications fails to provide Plaintiff with individualized notice of the censorship or an opportunity to be heard. Defendants did not provide constitutionally adequate notice of the basis for censorship of HRDC’s magazines nor did Defendants provide HRDC an opportunity to appeal the censorship decision with a party 13 Case No. 1:25-cv-00164 Document 1 filed 01/16/25 USDC Colorado pg 14 of 17 not involved in that original decision. Thus, Defendants violated HRDC’s clearly established right to due process. 44. Defendants’ conduct is objectively unreasonable and was undertaken recklessly, intentionally, willfully, with malice, and with deliberate indifference to the rights of others. 45. HRDC’s injuries and the violations of its constitutional rights were directly and proximately caused by Defendants’ policies and practices; and those policies and practices were the moving force behind the violations. 46. The acts described above have caused HRDC to suffer damages, and if not enjoined, will continue to cause HRDC to suffer damages. 47. HRDC seeks declaratory and injunctive relief against all Defendants, and nominal and compensatory damages against the individual Defendants. HRDC seeks punitive damages against the individual Defendants in their individual capacities. THIRD CLAIM FOR RELIEF Violation of Article II, Section 10 of the Colorado Constitution -- Free Speech Under C.R.S. 13-21-131 (Brought Against All Individual Defendants) 48. HRDC repeats and re-alleges each and every allegation set forth above, and incorporates them herein by reference. 49. At all relevant times, all Individual Defendants to this claim were acting under the color of state law, and each was a peace officer as defined by Colo. Rev. Stat. § 24-31-901(3). 50. The acts described above constitute violations of HRDC’s rights under Article II, Section 10 of the Colorado Constitution, which provides in relevant part that “No law shall be passed impairing the freedom of speech; every person shall be free to speak, write or publish whatever he will on any subject, being responsible for all abuse of that liberty.” 14 Case No. 1:25-cv-00164 51. Document 1 filed 01/16/25 USDC Colorado pg 15 of 17 HRDC has a liberty interest, protected by the Colorado Constitution, in communicating with incarcerated individuals by sending its materials, including the magazines Prison Legal News and Criminal Legal News, to them via U.S. Mail. Defendants’ unconstitutional censorship violates HRDC’s clearly established right to communicate with these individuals. 52. None of the content in any of the Plaintiff’s publications that Defendants have rejected violates the Detention Facility’s posted mail policy. Nor is there any other non-stated legitimate penological interest justifying Defendants’ unconstitutional censorship. 53. Moreover, Defendants’ apparent requirement that prisoners seek prior approval of published materials before they can be delivered to their intended recipients, supra ¶ 19, serves as a prior restraint on speech, abridging HRDC’s Colorado Constitutional right to free speech and communication. 54. Defendants’ conduct is objectively unreasonable and was undertaken recklessly, intentionally, willfully, with malice, and with deliberate indifference to the rights of others. 55. HRDC’s injuries and the violations of its Colorado constitutional rights were directly and proximately caused by Defendants’ policies and practices; and those policies and practices were the moving force behind the violations. 56. The acts described above have caused HRDC to suffer damages, and if not enjoined, will continue to cause HRDC to suffer damages. 57. HRDC seeks declaratory and injunctive relief against all Defendants, and nominal and compensatory damages against the individual Defendants. HRDC seeks punitive damages against the individual Defendants in their individual capacities. REQUEST FOR RELIEF WHEREFORE, Plaintiff respectfully requests relief as follows: 15 Case No. 1:25-cv-00164 1. Document 1 filed 01/16/25 USDC Colorado pg 16 of 17 A declaration that Defendants’ policies and practices violate the First and Fourteenth Amendments of the U.S. Constitution, as well as Article II, Section 10 of the Colorado Constitution, facially and as applied; 2. Preliminary and permanent injunctions preventing Defendants from continuing to violate the First and Fourteenth Amendments of the U.S. Constitution, as well as Article II, Section 10 of the Colorado Constitution, and providing other equitable relief; 3. Nominal damages for each violation of HRDC’s rights by the Individual Defendants; 4. Compensatory damages against the Individual Defendants in an amount to be proved at trial; 5. Punitive damages against the Individual Defendants in their individual capacities, in an amount to be proved at trial; 6. An award of costs, including reasonable attorneys’ fees, under 42 U.S.C. § 1988, C.R.S. 13-21-131(3), and other applicable law; and 7. Such further and additional relief as this Court may deem just and equitable. JURY DEMAND Plaintiff Human Rights Defense Center hereby demands a trial by jury pursuant to Federal Rule of Civil Procedure 38(b) on all issues so triable. 16 Case No. 1:25-cv-00164 Document 1 filed 01/16/25 Dated: January 16, 2025 USDC Colorado pg 17 of 17 Respectfully submitted, KILLMER LANE, LLP s/ Darold Killmer Darold Killmer Reid Allison 1543 Champa Street, Ste. 400 Denver, CO 80202 Telephone: (303) 571-1000 Fax: (303) 571-1001 dkillmer@killmerlane.com rallison@killmerlane.com Jonathan P. Picard* HUMAN RIGHTS DEFENSE CENTER P.O. Box 1151 Lake Worth, FL 33460 Telephone: (561) 360-2523 Fax: (561) 828-8166 jpicard@humanrightsdefensecenter.org Attorneys for Plaintiff Human Rights Defense Center *Admission pending. 17
