CERTIFICATE OF COMPLIANCE
I hereby certify that this brief complies with all requirements of C.A.R. 28 and C.A.R. 32, including all formatting requirements set forth in those rules. Specifically, I certify that this brief complies with C.A.R. 28(g) because it contains no more than 9,500 words. It complies with C.A.R. 28(k) because it contains under a separate heading: (1) a concise statement of the applicable standard of appellate review with citation to authority; and (2) a citation to the precise location in the record, not to an entire document, where the issue was raised and ruled on.
s/ Barry A. Schwartz
Barry A. Schwartz
Counsel of record for Defendant-Appellant, City and County of Denver
C.A.R. 28(e) directs that “[r]eferences to the electronic record shall be by ID number and appropriate page and line number.” This Court’s April 4, 2014 Policy on Citation to the Record provides conventions for citing to electronic records. Here, the record on appeal contains three portions – “court file,” “transcripts,” and minute orders. The “court file,” which consists of pleadings, motions and orders, contains no ID numbers,
, but the individual pages in the record are sequentially numbered on the bottom right as “COA 000XXX.” References to it will simply be to those page numbers. References to transcripts will follow the convention set forth in the Policy on Citation to the Record.