Martha M.

Tierney
Direct Dial: 303  376  3711 mtierney@hpgfirm.com

August 7, 2013 VIA EMAIL Scott Gessler Colorado Secretary of State 1700 Broadway, Ste 250 Denver, CO 80290 Re: Colorado Open Records Act Request Dear Secretary Gessler: I represent the Colorado Democratic Party and I am writing on its behalf. Pursuant to the provisions of the Colorado Open Records Act, C.R.S. §§ 24-72-201-402, this correspondence is a request for records, regardless of format, medium or physical characteristics. Specifically, I seek to inspect the following documents and records: All documents and communications, regardless of format and including but not limited to letters, lists, memoranda, and email, sent to or by the Colorado Secretary of State (or the Secretary of State’s staff, regardless of whether such correspondence was sent from an official or personal email account or otherwise), and received or sent by Jason Worley, Ken Clark, grassrootsradioco@yahoo.com, Alexander Hornaday or any other person with the @hornadaylaw.com email address, since January 1, 2013, concerning expenditures and expenses by state officials, including the Governor or the Office of the Governor. If the documents are available in electronic format, I am requesting electronic copies, preferably in their native format. If your office estimates the cost of providing any such records at more than $100, please notify me before proceeding with efforts to fulfill this request. If the public records described are not in your custody or control, you are requested to notify me in writing of that fact and to state in detail the reason for the absence of the records, the location of the records, and the person who has custody or control of the record, as required by C.R.S. § 24-72-203(2).

2401 15th Street, Suite 300 Denver, CO 80202 P: 303.595.4747 F: 303.595.4750

www.hpgfirm.com

Scott Gessler Colorado Secretary of State August 7, 2013 Page 2 of 2

In accordance with C.R.S. § 24-72-203, it is our understanding that access to records will be provided within a reasonable time, presumed to be three working days or less and not to exceed seven working days if extenuating circumstances exist. If you deny access to any of the above public records, please provide forthwith a written statement of the express grounds for the denial, citing the law or regulation under which access is denied, as required by C.R.S. § 24-72-204(4).

Very truly yours,

Martha M. Tierney

cc: Rick Palacio