IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADOCivil Action No.
THE INDEPENDENCE INSTITUTE,JON CALDARA,DENNIS POLHILL,JESSICA CORRYMASON TVERT,RUSSELL HAAS,DOUGLAS CAMPBELL, andLOUIS SCHROEDER,Plaintiffs,v.BERNIE BUESCHER, in his official capacity as Colorado Secretary of State,Defendant.
______________________________________________________________________________PLAINTIFFS, by and through counsel David A. Lane of K
LLP, respectfully allege for their Complaint as follows:
1. Colorado is one of several States that permits its citizens to place propositions on theballot through an initiative process. Colo. Const., Art. V, § 1; Colo. Rev. Stat. §§ 1-40-101 to 1-40-119 (1980 and Supp. 1987). In 2009 the Colorado Legislature passed HB 1326 (hereinafter“The Act”) (see attached) which Plaintiffs contend imposes unconstitutional limitations on theability of citizens to circulate petitions which would result in initiatives appearing on the ballot inthe general elections in November.
Case 1:10-cv-00609-PAB Document 1 Filed 03/16/2010 USDC Colorado Page 1 of 20