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Petition for Injunction

Petition for Injunction

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Published by Circuit Media

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Published by: Circuit Media on Jun 03, 2011
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01/04/2013

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SUPREME
COURT,
STATE
OF
COLORADO101
W.
Colfax
Ave.,
Suite
800
FILED
IN
THE
Denver,
Colorado
80202
SUPREME
COURT
ORIGINAL
PROCEEDING
IN
MAY
232011
UNAUTHORIZEDPRACTICE
OF
LAW,
OF
THE
STATE
OF
COLORADO
1
OUPLO58
Christopher
T.
Ryan,Clerk
Petitioner:
THE
PEOPLEOF
THE
STATE
OF
A
COURT
USE
ONLY
A
COLORADO
CaseNumber:
11SA154
Respondent:
DOUGLAS
BRUCE
Kim
E.
Ikeler,
#15590Assistant
Regulation
Counsel
Attorney
for
Petitioner
1560
Broadway,
Suite
1800
Denver,
CO
80202
Phone
Number:
(303)
866-6400
FaxNumber:
(303)
893-5302
Email:
k.ikelexJcsc
.
state.
co
.US
PETITION
FOR
INJUNCTION
Petitioner,
through
the
undersignedAssistant
RegulationCounsel,
and
upon
authorization
pursuant
to
C.R.C.P.234(a),l
respectfully
requests
that
the
Colorado
Supreme
Courtissuean
order
pursuant
toC.R.C.P.
234
directingtheRespondent
to
show
The
Unauthorized
Practice
of
Law(“UPL)Committee
authorized
the
filing
of
this
Petition
on
May
13,
2011.
 
cause
why
he
shouldnot
be
enjoined
from
theunauthorized
practice
of
law.
As
grounds
therefor,
counsel
states
as
follows:
Jurisdiction
1.
The
Respondent,
Douglas
Bruce,
is
not
licensed
to
practice
law
in
the
state
of
Colorado.
2.
Respondent
Bruce
is
an
inactiveCalifornia
attorney.
3.
Respondent’s
last
known
address
is
P.O.Box
26018,
Colorado
Springs,
Colorado
80936.
4.
Respondent
engagedin
the
unauthorized
practice
of
law,
as
described
below.
Factual
Allegations
5.
Respondent
Bruce
filed
an
action
against
the
City
of
Colorado
Springs,
seeking
injunctive
or
declaratory
reliefregarding
approval
of
language
for
a
ballotinitiative.Douglas
Bruce
v.
City
of
Colorado
Springs,El
PasoCounty
District
Court,
Case
No.
10CV260.
The
case
was
assigned
to
Judge
DavidGilbert,
who
denied
the
requested
relief
on
June
18,
2010.
6.
On
July
29,2010,
RespondentBruce
filed
an
almostidenticalcomplaint,
again
in
El
Paso
CountyDistrict
Court.
The
2
 
case
was
assigned
to
Judge
Theresa
Cisneros.
She
enteredan
orderinopen
courtdismissing
the
case.
Judge
Cisneros’
minute
order
stated
as
follows:
8/9/10:
CISNEROS:
CMD:
NETWORK
1:50
PM
HEAR:
TFPRO
SE;
ATIYWHITE
FORDEF;
HEARINGREGARDING
PTF’SCOMPLAINT
FOR
INJUNCTIVE
AND
DECLARATORY
RELIEF;
ATTY
WHITEMOVES
TO
DISMISS
THE
CASE
BECAUSE
PTF
FILED
THE
EXACTCOMPLAINT
IN
CASE
NO.
10CV260
IN
DIVISION
7.
ARGUMENTS;COURT
GRANTS
CITY’S
MOTION
TO
DISMISS.
PTF’S
REMEDY
WAS
TO
APPEAL
JUDGE
GILBERT’SRULING,NOTTO
FILE
A
NEWCASE.
THIS
CASE
ISBARRED
BY
THE
DOCTRINEOF
COLLATERAL
ESTOPPEL
AND
IS
THEREFORE
DISMISSED.
JUDGE
CISNEROS/TMC
7.
Respondent
Bruce
was
present
in
court
when
Judge
Cisneros
entered
her
order.
Respondent
stated
words
to
the
effect
that
hewas
going
to
have
othermembers
of
his
politicalactioncommittee
file
similar
lawsuits.
8.
On
August
12,
2010,
Helen
Collins,
an
ally
of
Respondent
Bruce,
filed
acomplaintnearly
identical
to
thecomplaints
in
the
Bruce
actions.
Helen
Collins
u.
City
of
Colorado
Springs,
El
Paso
County
DistrictCo urt,
Case
No.
10CV343
(the
“Collinscase).The
casewas
assigned
to
Judge
David
Miller.
9.
On
thesame
day,
August
12,
2010,Douglas
Stinehagen,
another
allyof
Respondent
Bruce,
filed
acomplaintnearly
identical
3

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